Tribunal Rules No Permanent Establishment in India; No Profits Attributable for Relevant Years.

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....Income deemed to accrue or arise in India - existence or otherwise of a Permanent Establishment (PE) in India - In fact, even at the stage of Tribunal, no contrary material has been brought on record by the Revenue to rebut the claim of the assessee that no PE existed in these years. - No profit shall be attributable - AT....