1992 (7) TMI 59

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....epresentative. However, the petitioner appended a note stating that the return claiming that the payments made to foreign buyers do not attract the provisions of the Income-tax Act, 1961. In the premises, payments made to foreign collaborators on account of lump sum consideration for technical know-how are neither royalty nor even for technical services under the provisions section 9(1)(vi) and se....

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....ssuance of the notice which are sufficient to clothe him with jurisdiction to proceed with the matter under section 148 of the Act. It was then argued that before notice under section 148 of the Act could be issued, a notice had to be issued to the petitioner under section 163(2) of the Act because under that provision, no person shall be treated as an agent of a non-resident unless he had had ....