https://www.taxtmi.com/caselaws?id=6509 A fresh contention based on business connection could not be entertained at the reference stage because a question of law not raised before, or considered by, the Tribunal does not arise from its order. For non-resident income, section 42 applies only where income accrues through or from a business connection and some connected operations are carried out in the taxable territories. On the findings, the technical information, research material and personnel services were furnished outside India, and no relevant operations were performed in India, so the fee beyond the amount already taxed was neither actually nor deemed to accrue or arise in India. The 5% addition already brought to tax remained undisturbed. en-us Mon, 11 Apr 1977 00:00:00 +0530 Tue, 17 Feb 2015 10:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6509 A fresh contention based on business connection could not be entertained at the reference stage because a question of law not raised before, or considered by, the Tribunal does not arise from its order. For non-resident income, section 42 applies only where income accrues through or from a business connection and some connected operations are carried out in the taxable territories. On the findings, the technical information, research material and personnel services were furnished outside India, and no relevant operations were performed in India, so the fee beyond the amount already taxed was neither actually nor deemed to accrue or arise in India. The 5% addition already brought to tax remained undisturbed. Case-Laws Income Tax Mon, 11 Apr 1977 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6509