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of Income accrues or arises or is deemed to accrue or arise - Mere construction of the track by Jaypee at its expense will be of no consequence. Its ownership or organising other events by Jaypee is also immaterial - Buddh International Circuit is a fixed place where the commercial/economic activity of conducting F-1 Championship was carried out - TDS was required to be deducted u/s 195 on the profit portion - SC
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