https://www.taxtmi.com/caselaws?id=62793 A composite compensation receipt under membership and service agreements was held not wholly taxable in India because the agreements were executed outside India, the non-resident had no office, personnel, or operations in India, and no business connection was established under section 9(1)(i). However, the word "Intercontinental" was treated as an intangible asset, and the agreements conferred a right to use that name, so an attributable portion of the consideration was taxable in India. The Tribunal also noted that rule 115B became relevant once part of the receipt was taxable, and the additional ground on interest loss was to be examined on verification and allowed on the same basis as comparable years. en-us Tue, 08 Mar 1983 00:00:00 +0530 Sun, 06 Feb 2011 02:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=62793 A composite compensation receipt under membership and service agreements was held not wholly taxable in India because the agreements were executed outside India, the non-resident had no office, personnel, or operations in India, and no business connection was established under section 9(1)(i). However, the word "Intercontinental" was treated as an intangible asset, and the agreements conferred a right to use that name, so an attributable portion of the consideration was taxable in India. The Tribunal also noted that rule 115B became relevant once part of the receipt was taxable, and the additional ground on interest loss was to be examined on verification and allowed on the same basis as comparable years. Case-Laws Income Tax Tue, 08 Mar 1983 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=62793