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    <title>2012 (5) TMI 125 - ITAT AHMEDABAD</title>
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    <description>Salary earned from a Polish company was treated as taxable in India because the assessee&#039;s role, though managerial in a general sense, was not a top level managerial position under Article 17(2) of the treaty; the additional evidence was also not admitted, so the exemption failed and the Revenue&#039;s addition was restored. Deduction under section 80G for cash donations was sustained because the assessee produced receipts and supporting material, and the disallowance rested only on an unsubstantiated assumption that cash resources were insufficient. The result was mixed, with the Revenue succeeding on the salary issue and the assessee succeeding on the donation issue.</description>
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      <title>2012 (5) TMI 125 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=213136</link>
      <description>Salary earned from a Polish company was treated as taxable in India because the assessee&#039;s role, though managerial in a general sense, was not a top level managerial position under Article 17(2) of the treaty; the additional evidence was also not admitted, so the exemption failed and the Revenue&#039;s addition was restored. Deduction under section 80G for cash donations was sustained because the assessee produced receipts and supporting material, and the disallowance rested only on an unsubstantiated assumption that cash resources were insufficient. The result was mixed, with the Revenue succeeding on the salary issue and the assessee succeeding on the donation issue.</description>
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