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Volkswagen Finance – An unusual interpretation of Business Connection

May 23, 2020[2020] 116 685 (Article)
The Mumbai Tribunal in Volkswagen Finance P Ltd v ITO [2020] 115 386 recently decided on the taxability of income earned by a Non Resident whose entire operations were carried on outside India. The decision was path breaking as the Tribunal did not follow the existing jurisprudence on the subject and deemed the payment made to the Non Resident u/s 9(1)(i) based on the amorphous nature of the term ‘business connection’.
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