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Section 172: Shipping Business in UAE Benefits from India-UAE DTAA; Residency Based on Registration, Not Nationality.

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....Applicability of provision u/s 172 for shipping business of non-resident - benefit as per DTAA between India & UAE - Merely Partner’s/Director’s nationality will not suffice the company’s residency when the company is registered and operational in a particular country in the present case is in UAE Dubai and has obtained the business licence from the said resident company is the resident of UAE. - AT....

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