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Sec. 10A relief denied on software development units on failure of assessee to prove that they were independent units
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Sec. 10A relief denied on software development units on failure of assessee to prove that they were independent units
Posted on
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June 30, 2015
Tenet Tax Daily June 27 2015
By
tenettax-team
Corporate Tax
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Order of Commissioner (Appeals) arriving at a conclusion that provisions of article 5 of DTAA of Indo-Netherland were not applicable without discussing actual work done by assessee required readjudication
Issue of shares by assessee at premium to its Mauritius AE did not give rise to income from an international transaction