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In Re : GEA Refrigeration Technologies GmbH, DorstenerStrasse 484 44809 Bochum Germany

Income chargeable to tax in India - income derived by the shareholders of Bock GmbH from the sale of shares of Bock GmbH, Germany - India-Germany DTAA - Bock GmbH, Germany holds 100 share capital of Bock India Private Limited - liability to TDS u/s 195 - Held that - Applicant s income cannot be brought to tax in India under the provisions of the Income tax Act 1961, as Bock GmbH derives its value substantially from its other companies situated in Germany, China, England, Czech Republic, Singapor....... + More



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