1996 (9) TMI 7

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..... s separately provided for and mentioned under separate sections - taxability of 1,65,000 U. S. dollars which is stipulated as the consideration for sale of trade secrets - agreement specifically says that the said sale is effected in Japan - it can not be said that any part of the said amount has been earned in India.
B. P. JEEVAN REDDY AND S. C. SEN JJ. For the Appellant : J. Ramamurthy, Seni .....

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..... y of 1,65,000 U. S. dollars which is stipulated as the consideration for sale of trade secrets. The agreement specifically says that the said sale is effected in Japan. We are unable to see on what basis it can be said that any part of the said amount has been earned in India. The appeal is dismissed. No costs. Civil Appeal No. 6943 of 1995 : For the reasons given in Civil Appeal No. 2350 of 19 .....

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