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    <title>2012 (7) TMI 404 - ITAT CHENNAI</title>
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    <description>Brokerage and commission earned by a non-resident from activities carried on outside India, and first received abroad through foreign correspondent banks before remittance to an Indian account, was held not taxable in India because the mode of transfer did not alter the place of first receipt and there was no business connection or permanent establishment in India. Alleged unexplained jewellery could not be added in the assessee&#039;s hands where the jewellery was found with other persons and the explanation of gifts and stridhan was not displaced; in any event, the funds were traced to non-taxable receipts. The tax additions were deleted and the Revenue&#039;s appeals failed.</description>
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      <description>Brokerage and commission earned by a non-resident from activities carried on outside India, and first received abroad through foreign correspondent banks before remittance to an Indian account, was held not taxable in India because the mode of transfer did not alter the place of first receipt and there was no business connection or permanent establishment in India. Alleged unexplained jewellery could not be added in the assessee&#039;s hands where the jewellery was found with other persons and the explanation of gifts and stridhan was not displaced; in any event, the funds were traced to non-taxable receipts. The tax additions were deleted and the Revenue&#039;s appeals failed.</description>
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