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He additional said that that Ld. DRP has accepted that when there may be permanent institution in India of the appellant then the receipts could be taxed solely as business earnings and never as fees for technical International Administration Group (UK) Restricted V ACIT ITA No 1613/Del/2015 A Y 2010-eleven ACIT v International Management Group (UK) Limited ITA No 1676/Del/2015 A Y 2010-11 Web page 17 of 72 providers.
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