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No Permanent Establishment in India for Activities Under DTAA Provisions, Assessed Annually Without Activity Restrictions.

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Full Text of the Document

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....PE in India - Grouting activities - he establishment of PE in India is in respect of each assessment year only. Moreover, there is no bar in carrying on the activities year after year. The determination of existence of PE in India is to be made by reference to provision in DTAA. - There is no PE....