Nonresident overseas entities' profits from services outside India not taxable u/s 9(1) or other provisions.

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....Since the nonresident overseas entities did not carry any activity or business operation in India, and they did not render any service in India, no portion of their business profits earned by them exclusively for services rendered outside India can be brought to tax in India, either u/s 9(1) or otherwise or at all. - AT....