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2009 (2) TMI 56 - HC - Income TaxChallenge to ruling of AAR – while the Authority has returned a finding of fact that none of the activities mentioned in Ex. (2) to S. 9(1)(1) is carried on by the petitioner in India, Authority then went on to apply the ratio of SC decision in case of R.D.Aggarwal to hold that activity of liaison offices of the petitioner constituted a 'business connection' in India and hence, income shall be deemed to accrue/arise in India - AAR has erred in applying the ratio of the decision of Supreme Court
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