2024 (7) TMI 1147

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..... act work done - outsourcing a portion of on-site work to its subsidiary in China - default u/s 201(1) 201(1A) - as decided by HC [ 2023 (6) TMI 773 - KARNATAKA HIGH COURT] person mentioned in section 195 of the Income Tax Act cannot be expected to do the impossible, namely, to apply the expanded definition of royalty inserted by explanation 4 to section 9(1)(vi) of the Income Tax Act, for the asse .....

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