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    <title>2023 (5) TMI 700 - ITAT MUMBAI</title>
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    <description>The Tribunal ruled in favor of the assessee, determining that the compensation payments made to Cricket South Africa (CSA) and Cricket Australia (CA) were not taxable in India. The Tribunal found that the payments were capital receipts and not attributable to operations in India, thus not subject to tax under Section 9(1) of the Income Tax Act, 1961. Furthermore, it was concluded that CSA did not have a Permanent Establishment in India, and there was no obligation for the assessee to deduct tax at source under Section 195. Consequently, the Tribunal set aside the orders of the CIT(A), allowing both appeals by the assessee.</description>
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    <pubDate>Thu, 11 May 2023 00:00:00 +0530</pubDate>
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      <title>2023 (5) TMI 700 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=437893</link>
      <description>The Tribunal ruled in favor of the assessee, determining that the compensation payments made to Cricket South Africa (CSA) and Cricket Australia (CA) were not taxable in India. The Tribunal found that the payments were capital receipts and not attributable to operations in India, thus not subject to tax under Section 9(1) of the Income Tax Act, 1961. Furthermore, it was concluded that CSA did not have a Permanent Establishment in India, and there was no obligation for the assessee to deduct tax at source under Section 195. Consequently, the Tribunal set aside the orders of the CIT(A), allowing both appeals by the assessee.</description>
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      <pubDate>Thu, 11 May 2023 00:00:00 +0530</pubDate>
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