Referral Fee Not Taxable in India: No Involvement of Mumbai PE in CSDB's Overseas Activity.

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....Income accrued in India - Referral fees - considering that the referral activity was undertaken outside India and assessee’s Mumbai branch (PE) had no role to play in the performance of the referral activity, the referral fee of ₹ 18,27,90,578/- earned by CSDB could not be construed to be attributable to assessee’s PE in India - No Tax liability in India - AT....