Supreme Court of India
Director of Income Tax, New Delhi v. M/s Mitsubishi Corporation
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From the headnote
Income Tax Act, 1961 – ss.190, 201, 209 and 234B – Proviso to s.209(1)(d), inserted by the Finance Act, 2012 – Interpretation of s.209 (1)(d) – The Respondent- Assessee is a no n-resident company incorporated in Japan, with operations in India – Notice was issued to the Respondent-Assessee u/s. 143 (2) of the Act on 12.10.2006 – An assessment order was passed for the years 1998- 99 to 2004-05 holding that a portion of the Assessee’s incom e was attributable to its activities in India and was therefore liable to be taxed in India, under Articles 4, 5 and 6 of the Doub le Taxation Avoidance
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