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No Permanent Establishment in India: Project Sites in Bangaluru and Gurugram Under 183-Day Threshold for Royalty Income.
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....Income deemed to accrue or arise in India - royalty income - permanent establishment (PE) in India - Each project site did not exceed threshold limit of 183 days. - The project sites at Bangaluru and Gurugram cannot be considered to be either installation or supervisory PE of the assessee in India. - The assessee in the year under consideration did not have any PE in India. - AT....