9911796707
TMI Blog2014 (3) TMI 1052X X X X Extracts X X X X X X X X Extracts X X X X ..... approach of the parties as is now confirmed by Hon'ble Supreme Court of India as well in the case of Commissioner of Income Tax & Anr Vs. Hyundai Heavy Industries Co.Ltd, [2007 (5) TMI 196 - SUPREME Court] that it is only the income of the business as is reasonably attributed to the operation carried out in India which can be said to be covered by subsection( 1) of section 9 of the Income Tax Act, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f the respondent. 2 We have perused Memo of Appeal, the order of the Assessment Officer, the order of the Commissioner of Income Tax (Appeals) and that of the Income Tax Appellate Tribunal. 3 We find that the question of law sated to be substantial and as formulated by the appellant in paragraph no.14(a) does not arise for consideration at all. 4 The department as also the assessee proceeded on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t it is only the income of the business as is reasonably attributed to the operation carried out in India which can be said to be covered by subsection( 1) of section 9 of the Income Tax Act, 1961. In the present case, as a finding of fact, it has been concurrently held that the receipts in US dollars mentioned in paragraph 4.2 of the Commissioner of Income Tax (Appeals) are not taxable. The only ..... X X X X Extracts X X X X X X X X Extracts X X X X
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