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    <title>1986 (6) TMI 15 - CALCUTTA High Court</title>
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    <description>The High Court held that the payment of 800,000 Canadian dollars received by the non-resident company for supplying know-how to Hindusthan Steel Ltd. was not taxable in India as it did not arise from any business connection in India. The court emphasized that the transaction for the supply of know-how occurred entirely outside India, and no income accrued within taxable territories in India. The court also affirmed that the supply of know-how and subsequent advisory services were separate transactions, with the former not establishing a business connection in India.</description>
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      <title>1986 (6) TMI 15 - CALCUTTA High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=26086</link>
      <description>The High Court held that the payment of 800,000 Canadian dollars received by the non-resident company for supplying know-how to Hindusthan Steel Ltd. was not taxable in India as it did not arise from any business connection in India. The court emphasized that the transaction for the supply of know-how occurred entirely outside India, and no income accrued within taxable territories in India. The court also affirmed that the supply of know-how and subsequent advisory services were separate transactions, with the former not establishing a business connection in India.</description>
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      <pubDate>Tue, 10 Jun 1986 00:00:00 +0530</pubDate>
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