Income Taxed in India Due to Permanent Establishment Under Indo-Spain Treaty, Article 5(1) and 5(iv.

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....Income accrued in India - PE in India - computers installed at the premises of the subscriber constitute a PE of the assessee in India in terms of Article 5 (1) of Indo-Spain Treaty. - since the Amadeus India is functionally dependent upon the assessee, it also constitute an agency PE in India in terms of Article 5 (iv) of the Indo-Spain Treaty.- AT....