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    <title>2022 (6) TMI 348 - ITAT MUMBAI</title>
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    <description>A non-resident&#039;s offshore distribution commission for procuring mutual fund subscriptions outside India was not taxable in India, because the services were rendered entirely abroad and no part of the relevant operations was carried out in India; the addition was deleted. Interest on rupee denominated bonds or government securities required fresh examination, as the factual basis for applying the lower rate under the relevant tax provisions had not been properly verified, and the matter was remanded for de novo adjudication. The appellate direction on education cess and higher education cess was upheld, as no infirmity was shown in requiring the Assessing Officer to follow the prevailing judicial view.</description>
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      <description>A non-resident&#039;s offshore distribution commission for procuring mutual fund subscriptions outside India was not taxable in India, because the services were rendered entirely abroad and no part of the relevant operations was carried out in India; the addition was deleted. Interest on rupee denominated bonds or government securities required fresh examination, as the factual basis for applying the lower rate under the relevant tax provisions had not been properly verified, and the matter was remanded for de novo adjudication. The appellate direction on education cess and higher education cess was upheld, as no infirmity was shown in requiring the Assessing Officer to follow the prevailing judicial view.</description>
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