The appeal of the assessee is allowed in the terms indicated as above
Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No. 73/Pan/2018 Assessment Year: 2012-13
permanent establishment which an enterprise of the other Contracting State has in the first-mentioned State at a rate of tax which is higher than that imposed on the profits of a similar enterprise of the first-mentioned Contracting State, nor as being in conflict with the provisions of paragraph 4 of Article 7 of this Convention. 3. Nothing contained