Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
Food import sampling requirements support provisional release where unseized consignments conform to standards and raw areca classification is unestab...
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Income Accrue or arise in India - FTS - the ultimate delivery of the software was outside India - Since there is no dispute that the services were rendered outside India to the customers outside India, no part of the income accrues or arises or deemed to accrue or arise in India and accordingly the provisions of section 5(2)(b) of the Act are not applicable in the instant case. - AT
Income Accrue or arise in India - FTS - the ultimate delivery of the software was outside India - Since there is no dispute that the services were rendered outside India to the customers outside India, no part of the income accrues or arises or deemed to accrue or arise in India and accordingly the provisions of section 5(2)(b) of the Act are not applicable in the instant case. - AT
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