Sec. 90 of Income Tax Act, 1961 - Double taxation relief – Since there was no PE's during the relevant asst. yr. 2007-08 for the activities relating to DPIR and engineering services from which the assessee earned the revenue and same cannot be taxed as business profit carried out through PE in India. It is in the nature of FTS which is to be taxed in accordance with Art. 13(4) of India-Spain DTAA. - IDIADA AUTOMOTIVE TECHNOLOGY V/s DY. CIT - [2020] 206 TTJ 114 (ITAT-DELHI)