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M/s Booz Allen and Hamilton (India) Ltd. & C. Kg (BAHI) is a foreign partnership firm, established in Germany. It had a branch office in India, through which, it carried certain management and consultancy services in connection with certain project works for Indian clients, part of which was done by its overseas group entities, including BAH USA. The AO treated BAHI as agent of BAH US entity and issued notice u/s 148 to BAHI. Pursuant thereof, a Nil return was file by BAHI India. The
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