Indo-French DTAA: Transactions at Arm's Length, Agent Deemed Independent Under Article 5(6), No Permanent Establishment Found.

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....Indo French DTAA - PE - Since there are no findings by the A.O., or the DRP, to the effect that the transactions between the agent and the assessee are not at an arm's length price, the agent is treated to be an independent agent in view of the provisions of Article 5(6). Such a finding by the revenue is a sine qua non for existence of PE - AT....