https://www.taxtmi.com/caselaws?id=37645 The High Court ruled in favor of the assessee-company, finding that they were not agents of the foreign company and that the interest accrued to the foreign company did not arise in India. The Tribunal's decision was upheld based on the lack of evidence showing a business connection beyond a solitary purchase transaction, leading to the conclusion that no interest income accrued to the foreign company in India. The department's arguments were not supported, and the High Court awarded costs to the assessee for the appeals. en-us Tue, 28 Mar 1978 00:00:00 +0530 Wed, 31 Mar 2010 11:38:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=37645 The High Court ruled in favor of the assessee-company, finding that they were not agents of the foreign company and that the interest accrued to the foreign company did not arise in India. The Tribunal's decision was upheld based on the lack of evidence showing a business connection beyond a solitary purchase transaction, leading to the conclusion that no interest income accrued to the foreign company in India. The department's arguments were not supported, and the High Court awarded costs to the assessee for the appeals. Case-Laws Income Tax Tue, 28 Mar 1978 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=37645