India's Equalization Levy Will Not Apply to Income Already Subject to Income Tax

MasterCard Asia Pacific Ltd. requested a stay on paying India’s 2% equalization levy, because the income could be subject to income tax in India if it was treated as having a permanent establishment in India (which is currently being contested). The full text of the application is reproduced below.
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MASTERCARD ASIA PACIFIC PTE. LTD.
Petitioner
Through: Mr. Harish N. Salve, Senior Advoc…
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