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    <title>1991 (6) TMI 11 - MADRAS High Court</title>
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    <description>Export incentive receipts were treated as accruing in Pondicherry because the underlying export activity was carried on wholly there, and mere later quantification at Bombay did not shift the place of accrual or receipt. For earlier assessment years, reassessment under the Income-tax Act, 1961 was barred where the same income had already been assessed under the French regime under paragraph 4 of the Pondicherry (Taxation Concessions) Order, 1964. For later years, paragraph 8 was construed to grant the concession on the assessee&#039;s entire income, as the Order did not express any territorial restriction for the relevant class of assessees.</description>
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    <pubDate>Tue, 11 Jun 1991 00:00:00 +0530</pubDate>
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      <title>1991 (6) TMI 11 - MADRAS High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=21449</link>
      <description>Export incentive receipts were treated as accruing in Pondicherry because the underlying export activity was carried on wholly there, and mere later quantification at Bombay did not shift the place of accrual or receipt. For earlier assessment years, reassessment under the Income-tax Act, 1961 was barred where the same income had already been assessed under the French regime under paragraph 4 of the Pondicherry (Taxation Concessions) Order, 1964. For later years, paragraph 8 was construed to grant the concession on the assessee&#039;s entire income, as the Order did not express any territorial restriction for the relevant class of assessees.</description>
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