2001 (11) TMI 975

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....ned deposits in the name of Nepali citizens in the Indian banks cannot be taxed under section 69 of the Income-tax Act, 1961. The main reason asserted by the Department is that it is not proved that the source of such deposit in the bank is actually in Nepal and not in India. The learned Departmental Representative submitted that on the basis of the enquiry conducted at the bank information was....

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....oidance agreement with Nepal. Learned counsel for the assessee submitted that the learned Commissioner of Income-tax (Appeals) had considered the facts and circumstances under the provisions of the law inasmuch as he has relied on articles 6 to 21 which form part of Chapter III under the head "Taxation of income". This provides for not taxing in India the deemed income of residents of Nepal. Th....