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Income Accrual from Software Solutions in India: No Additional Taxation Required Due to Arm's Length Principle Compliance.

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....Accrual of income in India - Provision of the software solutions for onward distribution to third party customers in India - since the appropriate ‘arm’s length principle’ has been satisfied in the present case, nothing more would be left to be taxable in India by attributing any further income to the PE of the assessee in India....