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1994 (9) TMI 127 - AT - Income TaxExtract: .......this clinches the issue. Thus having regard to the gamut of facts on record, since they were paid for the off period in a foreign country and since it is not relatable to the services rendered by them in India, we hold that the first appellate authority went wrong in holding that they are taxable in India. 6. In the result, the appeals are allowed.
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