Case Law Details
Case Name : Clifford Chance Vs DCIT (Bombay High Court)
Related Assessment Year :
Courts :
All High Courts Bombay High Court
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RELEVANT EXTRACTS:
34. For the purpose of taxation the authorities under the Act have proceeded on the basis that the fees received by the Appellant was for the entire Indian Project as such chargeable to tax.
35. Two basic questions which, thus, arise for our consideration are : (A) Whether fees charged for composite activity is chargeable to tax? and (B) Whether the income attributable to the services rendered by the Assessee/Appellant outside India required to be excluded while computing the tax in India?
36. The resolution of the above question would depend upon the interpretation of Claus...
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Please also refer explanation added to section 9 by the Finance Act 2007