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Sum received by Russian company for participating in oil pipelines project in India through PE was taxable: ITAT

June 25, 2019[2019] 106 114 (Delhi - Trib.)/[2019] 177 ITD 538 (Delhi - Trib.)

INTERNATIONAL TAXATION: Where assessee a Russia based company, participated in water supply augmentation project and oil pipeline project etc. through its PE in India, since there was no transfer of any technical know-how and, moreover, entire payment received during year was attributable to PE in India, same was taxable as business profit in terms of India-Russia DTAA

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