https://www.taxtmi.com/caselaws?id=57583 The court partially allowed Income-tax Appeal No. 414 (Bang.) of 1984 and fully allowed Income-tax Appeal No. 415 (Bang.) of 1984. The Commissioner (Appeals) was justified in deleting the addition related to the alleged business connection. The fees received by the non-resident company from the Indian company were held taxable as income deemed to accrue or arise in India under section 9(1) of the Income-tax Act, 1961, as they did not qualify for the exception provided under Explanation 2 to section 9(1)(vii). The cross-objections filed by the assessee were dismissed. en-us Thu, 19 Sep 1985 00:00:00 +0530 Fri, 10 Dec 2010 18:47:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=57583 The court partially allowed Income-tax Appeal No. 414 (Bang.) of 1984 and fully allowed Income-tax Appeal No. 415 (Bang.) of 1984. The Commissioner (Appeals) was justified in deleting the addition related to the alleged business connection. The fees received by the non-resident company from the Indian company were held taxable as income deemed to accrue or arise in India under section 9(1) of the Income-tax Act, 1961, as they did not qualify for the exception provided under Explanation 2 to section 9(1)(vii). The cross-objections filed by the assessee were dismissed. Case-Laws Income Tax Thu, 19 Sep 1985 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=57583