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1989 (11) TMI 40 - ALLAHABAD HIGH COURTExtract: .......e Court in the case of CIT v. Toshoku Ltd. 1980 125 ITR 525, in support of his contention that an income earned as commission by a non-resident company outside the country cannot be held taxable in India. That being so, we do not find any merit in the submission of the Department and this application under section 256 (2) is, accordingly, rejected.
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