Supreme Court: Income Taxable in India Only for Indian Operations u/s 9(1), Not Fully Supported by DTAA Article 7.

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....Income taxable in India - Income attributable to the operations carried out in India - Article 7 of DTAA with USA, may not really go to the rescue of the Revenue for the reason that in the contracting state, the entire income derived by the respondents, namely, USD/EURO 3 will be taxable. This is why Section 9(1) confines the taxable income to that proportion which is attributable to the operations carried out in India. - SC....