Income from ONGC contract not taxable in India; High Court finds no PE involvement for foreign work.

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....Taxability of income earned by the Assessee in respect of a contract entered into by it with ONGC Limited, a public sector enterprise (hereafter ‘ONGC’) - There is also no material to indicate that the work done outside India included any input from the Assessee's PE in India. - Not taxable - HC....