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The issue arising for consideration before the Tribunal was, whether in the year under consideration the assessee had a PE in India?

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Sec. 9 of Income Tax Act, 1961—Income—Income deemed to accrue or arise in India - Tribunal has recorded a finding of fact that the details of income attributable to services rendered in India and outside India were furnished before the Assessing Officer and the Assessing Officer has found them to be in order and there is no finding by the Assessing Officer regarding assessee’s claim that its employees / personnel stayed in India for rendering services for a period of 42 days, thus, the assessee did not have any PE in India. - LINK LETERS LLP V/s DY. CIT - [2020] 183 ITD 156 (ITAT-MUMBAI)

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