2000 (6) TMI 10

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....ion 195(2) of the Income-tax Act, 1961, seeking directions from the Assessing Officer to decide as to what portion of remittance made to Universal Parcel Services Worldwide Forwarding Inc., a non-resident company, would constitute income chargeable to tax in India in the hands of the said non-resident company. The Tribunal has come to the conclusion that in the present matter, on facts, no part of....