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Jayanta Bandyopadhyay   23 February 2022

Dtaa, residential status

Foreign service provider gives Form 10F and DTAA Declaration that they do not have PE in India and no representative stays here 99 days above in FY.

but they have one under freelancer agreement, who coordinates, renders tech expertise on their behalf. Even participates in negotiation meeting.

Then is it not a wrong statement. Can freelancer break that PERMANENT ESTABLISHMDNT AND 90 DAYS CRITERION?



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