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1996 (9) TMI 7 - SCH - Income TaxAgreement is in two parts - two parts are interdependent but yet the consideration for the sale of trade secrets & consideration of technical assistance is separately provided for and mentioned under separate sections - taxability of 1,65,000 U. S. dollars which is stipulated as the consideration for sale of trade secrets - agreement specifically says that the said sale is effected in Japan - it can not be said that any part of the said amount has been earned in India.
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