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1999 (2) TMI 17 - SC - Income TaxAssessee, English company, entered into an agreement with an Indian company - assuming that the assessee had a business connection in India, in view of the provisions of Explanation (a) of section 9, only that part of the income could be brought to tax in India which was reasonably attributable to the operations carried out in India - since after the lapse of almost 40 years, it would be impossible to determine the extent of the activity carried on in India , revenue's appeal is dismissed
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