2014 (3) TMI 1052

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....lla, Sr. Counsel with Mr.Parag Vyas for the respondent. JUDGEMENT 1 Heard Mr.Suresh Kumar, learned counsel appearing on behalf of the appellant and Mr.Pardiwalla, learned Sr. Counsel appearing on behalf of the respondent. 2 We have perused Memo of Appeal, the order of the Assessment Officer, the order of the Commissioner of Income Tax (Appeals) and that of the Income Tax Appellate Tribuna....

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....tent understanding and approach of the parties as is now confirmed by Hon'ble Supreme Court of India as well in the case of Commissioner of Income Tax & Anr Vs. Hyundai Heavy Industries Co.Ltd, (2007) 291 ITR 482 that it is only the income of the business as is reasonably attributed to the operation carried out in India which can be said to be covered by subsection( 1) of section 9 of the Inco....