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2007 (10) TMI 175 - HC - Income TaxCBDT circular 1767/87 providing that 1 % of the receipt by foreign co., shall be applied to determine deemed profits and gains u/s 44BB, is void – CBDT is not empowered to fix the percentage for calculating the deemed profit u/s 44BB – held that 10 % of the mobilization charges for transportation of vessel outside the territorial waters of India would be taxable
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