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    <title>2010 (6) TMI 637 - ITAT MUMBAI</title>
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    <description>Entitlement to a no-deduction certificate for remittance to Institut Francais Du Petrole, France, turned on whether the recipient was a department of the French Government and whether it was carrying on commercial activity. The Tribunal noted earlier no-deduction certificates and supporting certificates from French tax authorities and the French Embassy stating that the recipient was under French Government control and not taxable in France on the relevant income, but found the record insufficient to conclusively establish those claims. The matter was restored to the Assessing Officer for fresh consideration after allowing the assessee an opportunity to file supporting evidence.</description>
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      <link>https://www.taxtmi.com/caselaws?id=122171</link>
      <description>Entitlement to a no-deduction certificate for remittance to Institut Francais Du Petrole, France, turned on whether the recipient was a department of the French Government and whether it was carrying on commercial activity. The Tribunal noted earlier no-deduction certificates and supporting certificates from French tax authorities and the French Embassy stating that the recipient was under French Government control and not taxable in France on the relevant income, but found the record insufficient to conclusively establish those claims. The matter was restored to the Assessing Officer for fresh consideration after allowing the assessee an opportunity to file supporting evidence.</description>
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