MFPM's Equipment Sale Income Not Taxable in India; No Income Attributed to Indian Operations per Section 9(1)(i).

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....Income taxability in India - even if for the sake of argument, it is assumed that MFPM has a business connection in India, it cannot be said that the income is deemed to accrue or arise in India as per Section 9(1)(i) of the Act, as no part of the income earned by MFPM from sale of equipment in India is attributable to the operations carried out in India - AAR....