Section 10A and related deductions: Tribunal rejects separate-undertaking claim, but allows loss set-off, ESOP cost and foreign tax credit in principl...
Income accrued in India or not - the effective management of the assessee is neither in Mauritius nor in India - if the effective management of an enterprise is not in one of the contracting state, but is situated in the third state, the benefit of article-8, cannot be extended. - AT
Income accrued in India or not - the effective management of the assessee is neither in Mauritius nor in India - if the effective management of an enterprise is not in one of the contracting state, but is situated in the third state, the benefit of article-8, cannot be extended. - AT
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