Court Rules Section 44DA Addition Unjustified: Technical Services Fees Not Effectively Connected with Indian Permanent Establishment.

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....Addition u/s 44DA - PE/Business Connection of the assessee - scope of phrase 'effectively connected with' - the assessee has offered the fee for technical services on gross basis and the activities conducted outside India are not effectively connected with PE in India, therefore, the addition made under Section 44DA of the I.T. Act is liable to be deleted - AT....