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    <title>1987 (6) TMI 92 - ITAT DELHI-C</title>
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    <description>The Tribunal upheld the Commissioner of Income-tax (Appeals)&#039; decision that the remittance for foreign technicians&#039; expenses under a foreign collaboration agreement was not taxable under the Income-tax Act, 1961. The Tribunal determined the payment was in the nature of salary, falling under an exemption provision, and not subject to tax liability. Additionally, the Tribunal rejected the Department&#039;s attempt to introduce additional grounds of appeal under section 195(2), ruling that these grounds were inadmissible as they were not raised by the Commissioner of Income-tax. Despite this, the Tribunal found that even if considered, the Department&#039;s additional grounds would not succeed. The appeal was ultimately dismissed.</description>
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    <pubDate>Tue, 30 Jun 1987 00:00:00 +0530</pubDate>
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      <title>1987 (6) TMI 92 - ITAT DELHI-C</title>
      <link>https://www.taxtmi.com/caselaws?id=63915</link>
      <description>The Tribunal upheld the Commissioner of Income-tax (Appeals)&#039; decision that the remittance for foreign technicians&#039; expenses under a foreign collaboration agreement was not taxable under the Income-tax Act, 1961. The Tribunal determined the payment was in the nature of salary, falling under an exemption provision, and not subject to tax liability. Additionally, the Tribunal rejected the Department&#039;s attempt to introduce additional grounds of appeal under section 195(2), ruling that these grounds were inadmissible as they were not raised by the Commissioner of Income-tax. Despite this, the Tribunal found that even if considered, the Department&#039;s additional grounds would not succeed. The appeal was ultimately dismissed.</description>
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      <pubDate>Tue, 30 Jun 1987 00:00:00 +0530</pubDate>
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