Income Accrued in India Confirms Permanent Establishment Under Business Service Agreement, Following OECD Commentary on Article 5(2)(1).

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....Income accrued in India - PE in India - business service agreement/single unified agreement - On going through the sequence of activities and commentary of the OECD with regard to the Article 5(2)(1), it can be concluded that the activities consists of same and enter-connected projects. - Thus, based on the unified agreement, consolidated billing pattern, the activities being inter related as found in the preceedings paras, we hereby hold that the existence of the PE of the assessee is undeniable. - AT....