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The ITAT Chennai ruled that for income to fall under the second exception of section 9(1)(vii)(b), the source of income must be outside India, not just the receipt. The case involved Alstom T & D India Ltd., which was disallowed TDS deductions on payments made to foreign testing agencies for design tests, as the source of income was determined to be in India due to the conclusion of export contracts there. The tribunal upheld the Assessing Officer

Author
parshah34
Language
EN

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