Expenditure incurred by a foreign company in India during period of lull in its business in India not allowable

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6. Admittedly, the assessee in these appeals are non-resident companies having no permanent establishment in India. It is also not disputed that after the contract received by the assessee companies in the year 1983 and before, fresh contract was given to them by the ONGC only in the year 1999. Learned counsel for the appellant (revenue) argued that since the respondent / assessee did no business in India between 1993 to 1998, as such, they ca

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