Software Income Not Taxable in India Without Dependent Agent PE, Affirms Consistent Rulings and Coordinate Bench Decision.

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....Income taxable in India - existence of dependent agent PE - here is no gainsaying that factually the issue stands on identical footing in relation to preceding assessment years, as, both the Assessing Officer and learned DRP have decided the issue following their earlier decisions. That being the case, respectfully following the decision of the coordinate Bench, as referred to above, we hold that the amount received by the assessee from supply of software and automated services, are not taxable in India. - AT....