2014 (2) TMI 1419

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..... d this accrual of income has taken place in Japan. As such, the Income Tax Act cannot be made applicable. We feel that the decision is legally correct and we do not find any element of law to be decided in this appeal. The appeal is accordingly dismissed. - I.T.T.A. No. 612 of 2013 - - - Dated:- 4-2-2014 - THE HON BLE THE CHIEF JUSTICE SRI KALYAN JYOTI SENGUPTA AND THE HON BLE SRI JUSTICE S .....

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..... ndent assessee is not liable for tax in India, is not vitiated in law as the Hon ble Tribunal failed to consider and appreciate the material facts and reasons on record ? We have heard Mr. B. Narasimha Sarma, learned counsel for the appellant and have gone through the judgment and order of the learned Tribunal. It appears, the learned Tribunal, on fact, found that there has been no accrual o .....

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