India-Germany DTAA: Income from Supervision Services Not Taxable as PE or Royalty; AO/DRP Decision Overturned.

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....Income taxable in India - Existence of Permanent establishment (PE) - royalty/fee for technical services (FTS) - India-Germany DTAA - income from supervision services for inspection/optimization/erection/commissioning repair in India to other parties - AO/DRP is not justified in holding that assessee has used the premises of its associate company in India for rendering services to its clients. - AT....