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of The issue pertains to whether the amounts received as sales commission by a non-resident assessee are in the nature of fees for included services, and whether such income accrued or arose in India. The court held that the case is covered by the decisions in Toshoku Ltd. and Evolv Clothing Co.(P). Ltd., which dealt with Section 9(1)(i) of the Act and its Explanation (a). If all operations are carried out in India, the entire income is deemed to accrue in India. However, if operations are not entirely carried out in India, only the part of income reasonably attributable to operations in India is deemed to accrue in India. If no operations are carried out in the taxable territories, income accruing abroad through business connection in India cannot be deemed to accrue in India. The decision was in favor of the assessee.
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