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    <title>2000 (1) TMI 139 - ITAT CALCUTTA-E</title>
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    <description>The Tribunal held that only a proportionate amount of payments made by PILCOM should be considered for tax deduction under Section 194E and 201(1) of the Income-tax Act. It was determined that payments to countries not participating in India should be excluded, and for countries playing in India, a ratio of matches played in India to total matches should be applied. The Tribunal also clarified that payments to countries with Double Taxation Avoidance Agreements should be taxed proportionately. The Tribunal emphasized the extraterritorial jurisdiction of Indian tax laws, stating that income generating taxable income in India is subject to tax regardless of payment location.</description>
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      <title>2000 (1) TMI 139 - ITAT CALCUTTA-E</title>
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