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Further, the negotiations of prices also took place in India. He further found that GE Overseas, by remotely sitting in foreign countries, could not make any sales, without the active involvement of GE India. The AO, therefore, held that all the profits did not accrue or arise to the assessee in the foreign soil, but part of such profits arising in India, corresponding to the activities carried out in India, was chargeable to tax under the Act.
Such income accruing or arising was held to be liable to tax as per the provisions of section 5 2 of the Act. Thakkar aged 38 years furnishes the following details with regard to his options exercised for tax planning purpose for the year ending as on Chattur, is a citizen of Germany came to India as a tourist in the previous year and stayed in India for a period of days.
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