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Commissioner Of Income-Tax, Punjab vs R. D. Aggarwal & Company on 6 October, 1964

a) In (1965) 56 ITR 20 (SC) CIT Vs. R.D. Agarwal & Co. it was held that a business connection involves a relation between a business carried by a non-resident which yields profit or gains and some activity in the taxable territories which contributes directly or indirectly to the earning of those profits or gains. It postulates a real and intimate relation between trading activity carried on outside the taxable territories the relation between the two contributing to the earning of income by the non-resident in his trading activity.
Supreme Court of India Cites 20 - Cited by 173 - J C Shah - Full Document

Commissioner Of Income-Tax, Tamil ... vs Fried Krupp Industries on 2 May, 1980

In 1981 (128) ITR 27 (Commissioner of Income-tax Vs. Fried Krupp Industries) this Court held, "that there were no operations in India which were attributable to the foreign Company which could give rise to any profits being earned in India. The terms of the agreement made it clear that none of the three types of activities of the foreign company resulted in business connection in India:
Madras High Court Cites 11 - Cited by 55 - Full Document
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