1990 (8) TMI 136

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....tution of India, the petitioner has challenged the legality and validity of the letter dated September 12, 1986, issued by the Ministry of Finance, Department of Revenue, Foreign Tax Division, Government of India, New Delhi. The petitioner had entered into two agreements dated November 3, 1980, and September 1, 1981, with the Ontario Paper Company Limited of Canada for rendering services to tha....

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....wo agreements. By its impugned letter dated September 12, 1986, the Government rejected the application in the following terms: "I am directed to refer to your application dated March 4, 1986, and subsequent submissions dated June 5, 1986, on the above subject and to say that you have not rendered any service outside India as a technician within the meaning of section 80RRA of the Income-tax Ac....