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Adit Cir 2(2), Mumbai vs Taj Tv Ltd, Mumbai on 23 December, 2016

-98 arid AY 2000-01. The appellant's AR has made similar set of submissions as it was submitted that by him in the appellate proceedings for A.Ys.2007-08 and 2000-01, which has already been adjudicated as referred above. Thus, I find that the issue involved in these grounds of appeal has been decided in favour of the appellant by my predecessor CIT(A) in A,Ys 1997-98 and 2000-01 keeping reliance on decision of the jurisdictional ITAT, Mumbai's decision in A.Ys. 2001-02 and 2002-03. This, following the rule of consistency, I consider it proper and appropriate to be in agreement with my predecessor GIT(A)s decision and accordingly hold that the appellant does not have a business connection in India as the MBIPL does not constitute a business connection of the appellant in India u/s.9 of the Act and, therefore, its income in respect of sale of CBU cars directly to the customers in India is not taxable in India.
Income Tax Appellate Tribunal - Mumbai Cites 32 - Cited by 24 - Full Document
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