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1998 (11) TMI 95 - HC - Income TaxExtract: ....... mentioned in art. III(a) of the collaboration agreement did not accrue or arise in India to WEAN United within the meaning of s. 5(2)(b). I, would, therefore, answer the reference in the negative, that is to say, in favour of the assessee and against the Revenue. 14. In the facts of the case, I will make no order as to costs. S.N. JHA, J. I agree.
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