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    <title>2015 (4) TMI 670 - ITAT DELHI</title>
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    <description>Consistent MAP-based treatment of identical advertisement and subscription receipts justified taxing only 10% of the revenues as business income in India, since the same receipts had been accepted on a business-income basis in earlier and later years and no perversity was found in following that approach. For a non-resident whose income was fully subject to tax withholding under section 195, no advance tax obligation arose and interest under section 234B could not be levied. The relief granted to the assessee was therefore sustained on both issues.</description>
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      <link>https://www.taxtmi.com/caselaws?id=258789</link>
      <description>Consistent MAP-based treatment of identical advertisement and subscription receipts justified taxing only 10% of the revenues as business income in India, since the same receipts had been accepted on a business-income basis in earlier and later years and no perversity was found in following that approach. For a non-resident whose income was fully subject to tax withholding under section 195, no advance tax obligation arose and interest under section 234B could not be levied. The relief granted to the assessee was therefore sustained on both issues.</description>
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      <pubDate>Wed, 25 Mar 2015 00:00:00 +0530</pubDate>
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