R&D Activities Do Not Create Permanent Establishment in India; Taxable Only if Profits Accrue Locally - Article 7(1.

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....PE in India - activities of Research and development activities do not constitute a PE of the assessee in India - A plain reading of the Article 7(1) would show, that the issue of taxability would arise qua the respondent/assessee only if profits accrue to the respondent/assessee, and that too only to the extent they can be attributed to its PE in India. - HC....