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Flores Gunther Vs. Income-tax Officer

Court : Income Tax Appellate Tribunal ITAT Hyderabad

Reported in : (1987)22ITD504(Hyd.)

..... with italian company more particularly para 12.1 of the agreement would clearly show that apart from payment of fees for transfer of technical know-how the payment which bhel is obliged to pay under annexure 6 are all payable to italian company and the whole payment is towards technical know-how fee.17. now let us see the terms of the agreement ..... -mentioned state if : (a) the recipient is present in the other state for a period or periods not exceeding in the aggregate 183 days in the fiscal year concerned, and (b) the remuneration is paid by or on behalf of, an employer who is not a resident of the other state, and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other state.even in case of technocrats deputed by the ..... engaged in any trade or business in india ; (b) his stay in india does not exceed in the aggregate a period of ninety days in such previous year ; and (c) such remuneration is not liable to be deducted from the income of the employer chargeable under this act.it is not the case of the revenue that any of three foreign collaborators with whom we are concerned here are either engaged in trade or business in india ..... that means, in our case limitation should be computed from 1-4-1983 and the time would be available up to 31-3-1985.in support of the proposition that a provision regarding limitation always represents a procedural law reliance was placed upon the ..... government of india undertaking had entered into .....