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“non-resident”

Chapter I - PreliminarySection 2 - DefinitionsSection 2(30) / Section 6 / ITR Forms3,736 judgments

The decision most relied on for non-resident is GE India Technology Centre Pvt. Ltd. v. CIT (327 ITR 456), cited in 663 judgments on BharatTax.

Leading authorities on non-resident

GE India Technology Centre Pvt. Ltd. v. CIT
327 ITR 456 · 2010 · Supreme Court
663
citing judgments

Tax must be deducted at source from payments made to a non-resident under Section 195 only if such payment is chargeable to tax in India. The Assessing Officer bears the onus to establish that the payments made are indeed chargeable to tax under the Income Tax Act.

CIT v. Samsung Electronics Ltd.
345 ITR 494 · 2012 · High Court
461
citing judgments

Payments by Indian residents to non-resident foreign software suppliers for software are considered royalty, constituting income deemed to accrue in India under section 9(1)(v), thereby requiring tax deduction at source under section 195.

Ishikawajima Harima Heavy Industries Ltd. v. DIT
288 ITR 408 · 2007 · Supreme Court
394
citing judgments

Income from offshore supply of goods and services is not taxable in India if the entire transaction, including transfer of ownership and payments, occurs outside India.

CIT v. De Beers India Minerals (P.) Ltd.
346 ITR 467 · 2012 · High Court
371
citing judgments

For fees for technical or consultancy services to 'make available' technical knowledge or know-how under a DTAA, the service must transmit such knowledge, allowing the recipient to derive an enduring benefit and utilize it independently in the future.

CIT v. Toshoku Ltd.
125 ITR 525 · 1980 · Supreme Court
270
citing judgments

A non-resident commission agent is not chargeable to tax in India on commission income if no business operations are carried out in India. Consequently, no TDS is required under Section 195 on such payments.

DIT v. Infrasoft Ltd.
39 Taxmann.com 88 · 2013 · High Court
269
citing judgments

Payments for the use of copyrighted software, without the transfer of any rights in the underlying copyright itself, do not constitute 'royalty' under the Income-tax Act or tax treaties. Such payments are often treated as business income, taxable only if a permanent establishment exists.

Transmission Corporation of Andhra Pradesh v. CIT
239 ITR 587 · 1999 · Supreme Court
243
citing judgments

The Supreme Court lays down principles for deducting tax at source (TDS) under Section 195 on payments to non-residents, including aspects of income deemed taxable in India and the application of Double Taxation Avoidance Agreements (DTAAs) under Section 90.

ONGC v. CIT
376 ITR 306 · 2015 · Supreme Court
241
citing judgments

Income derived by a non-resident for services related to mineral oil operations, falling under the presumptive taxation regime of Section 44BB, cannot simultaneously be treated as fees for technical services under Section 9(1)(vii). The specific presumptive provisions override the general FTS definition, particularly when DTAA applies.

Judgments citing non-resident

Pralay Pradyotkanti Ghosh, Ahmedabad vs. Income -Tax Officer, Ward-1, International Taxation, Ahmedabad

In the result, the appeal of Assessee is partly allowed

ITA 298/AHD/2022[2018-19]Status: DisposedITAT Ahmedabad12 Jul 2024AY 2018-19

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokar, Accountnat Member आयकर अपील सं /Ita No.298/Ahd/2022 "नधा"रण वष" /Assessment Year : 2018-19 Pralay Pradyotkanti Ghosh The Ito बनाम/ 22, Konark Society Ward-1 Nr. Railway Colony International Taxation V/S. Jawahar Chowk, Sabarmati Ahmedabad Ahmedabad – 380 019 "थायी लेखा सं./Pan: Abypg 6172 C (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Bandish Soparkar, Ar Revenue By : Shri Atul Pandey, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 27/06/2024 घोषणा क" तार"ख /Date Of Pronouncement: 12/07/2024 आदेश/O R D E R Per Shri Makarand V. Mahadeokar, Am: This Appeal Is Filed By The Assessee As Against The Order Passed By The Ld.Commissioner Of Income-Tax(Appeals)-13, Ahmedabad [Hereinafter Referred To As “The Ld.Cit(A)”], Dated 01/06/2022, Arising Out Of The Assessment Order Passed By The Assessing Officer (Ao) Under Section 143(3) R.W.S.144C(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As "The Act") Dated 22/10/2021 Relevant To The Assessment Year (Ay) 2018-19. Pralay Pradyotkanti Ghosh Vs. Ito (Intl.Taxation) Asst. Year : 2018-19

For Appellant: Shri Bandish Soparkar, ARFor Respondent: Shri Atul Pandey, Sr.DR
Section 139(1)Section 143(3)Section 192Section 2Section 5(2)(b)

relationship between "Oceaneering" with the appellant is cvident from the terms and conditions filed during appeal proceedings. The appellant has claimed to be a non-resident which has not been disputed by the AO, hence is covered under the scope of section 5(2) of the Act which states ... India. 2) Subject to the provisions of this Act, the total income of an previous year of a person who is a non-resident includes all income from whatever source derived which- (a) is received or is deemed to be received in India in such year by or on behalf

DCIT, Circle-2(1)(1), Ahmedabad vs. Elitecore Technologies Private Limited, Ahmedabad

In the result, the appeal filed by the Revenue is dismissed

ITA 1728/AHD/2019[2011-12]Status: DisposedITAT Ahmedabad12 Jul 2024AY 2011-12

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokar, Accountnat Member आयकर अपील सं /Ita No.1728/Ahd/2019 "नधा"रण वष" /Assessment Year : 2011-12 The Dy.Cit Elitecore Technologies Pvt.Ltd. Circle-2(1)(1) बनाम/ (Now Merged With Sterlite Ahmedabad Technolgies Limited) V/S. 904, Silicon Tower, B/H. Pariseema Building Off. C.G. Road Ahmedabad, Gujarat-380 009 "थायी लेखा सं./Pan: Aaace 6815G (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Dhinal Shah, Ar Revenue By : Shri Atul Pandey, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 27/06/2024 घोषणा क" तार"ख /Date Of Pronouncement: 12/07/2024 आदेश/O R D E R Per Shri Makarand V. Mahadeokar, Am: This Appeal Is Filed By The Revenue As Against The Order Passed By The Ld.Commissioner Of Income-Tax(Appeals)-10, Ahmedabad [Hereinafter Referred To As “The Ld.Cit(A)”], Dated 04/09/2019, Arising Out Of The Assessment Order Passed By The Assessing Officer (Ao) Under Section 143(3) Dcit Vs. Elitecore Technologies Pvt.Ltd. Asst. Year : 2011-12

For Appellant: Shri Dhinal Shah, ARFor Respondent: Shri Atul Pandey, Sr.DR
Section 143(2)Section 143(3)Section 195Section 250Section 40Section 92C

Revenue’s appeal are dismissed. On Ground No.3 8. This ground relates to disallowance of Product Certification Expenses of Rs.60,57,180/- paid to non-resident on account of non-deduction of withholding tax u/s 195 of the Act and non-genuineness of the expenditure. 8.1 The facts are such ... order about the same. 8.10. It is noted that the assessee incurred Product Certification Expenses amounting to Rs.60,57,180/- paid to non-resident entities from the USA, UK, Korea, and China. Payments were made for certification services which involved evaluating and certifying the technical quality of the software product

The Dy.DIT, (Intl. Taxn.)- 1, Ahmedabad vs. Vodafone West Ltd., Ahmedabad

In the result, appeal of the Revenue stands dismissed

ITA 2398/AHD/2014[2013-14]Status: DisposedITAT Ahmedabad12 Jul 2024AY 2013-14

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar, Accountnat Member आयकर अपील सं /Ita No.2398/Ahd/2014 "नधा"रण वष" /Assessment Year : 2013-14 The Dcit (International Vodafone West Ltd. बनाम/ Taxation)-1 Vodafone House Ahmedabad Corporate Road V/S. Prahladnagar Off S.G. Highway Ahmedabad-380 051 "थायी लेखा सं./Pan: Aaacf 1190 P अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Dinal Shah, Ar Revenue By : Shri Sudhakar Verma, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 04/07/2024 घोषणा क" तार"ख /Date Of Pronouncement: 12/07/2024 आदेश/O R D E R Per Shri Makarand V. Mahadeokar, Am: This Appeal Is Filed By The Revenue As Against The Order Passed By The Ld.Commissioner Of Income-Tax(Appeals)-Gandhinagar (Ahmedabad) [Hereinafter Referred To As “The Ld.Cit(A)”], Dated 02/06/2014, Arising Out Of The Assessment Order Passed By The Dy.Director Of Income-Tax (International Taxation)-1, Ahmedabad (Ao) Under Section 201(1) & 201(1A) The Dcit (Intl.Taxn.)-1 Vs. Vodafone West Ltd. Asst. Year : 2013-14

For Appellant: Shri Dinal Shah, ARFor Respondent: Shri Sudhakar Verma, Sr.DR
Section 195(1)Section 201(1)Section 9(1)Section 9(1)(vi)Section 90

these cases. 169. Our answer to the question posed before us, is that the amounts paid by resident Indian end-users/distributors to non-resident computer software manufacturers/suppliers, as consideration for the resale/use of the computer software through EULAs/distribution agreements, is not the payment of royalty ... under End User License Agreements (EULAs). Section 195 of the Income Tax Act, 1961, mandates the deduction of tax at source on payments to non-residents, only when such payments are chargeable to tax in India. The payments made in the present case do not fall under the definition

Nachimuthugownder Balasamy Karthikeyan, Erode vs. ITO, International Taxation Ward, Coimbatore

In the result, the appeal stand partly allowed

ITA 428/CHNY/2024[2018-19]Status: DisposedITAT Chennai10 Jul 2024AY 2018-19

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.428/Chny/2024 (िनधा9रणवष9 / Assessment Year: 2018-19) Shri Nachimuthugownder Balasamy Ito बनाम/ Karthikeyan International Taxation Ward, 66, Kovalan 2Nd Street, Coimbatore. Vs. Teachers Colony, Erode-638 011. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aotpk-3606-H (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Appellant By : Shri S.Sridhar (Advocate) Erode - Ld.Ar " थ"कीओरसे/Respondent By : Shri Nilay Baran Som (Cit) - Ld. Dr सुनवाई की तारीख/Date Of Hearing : 20-06-2024 घोषणा की तारीख /Date Of Pronouncement : 10-07-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

For Appellant: Shri S.Sridhar (Advocate) Erode - Ld.ARFor Respondent: Shri Nilay Baran Som (CIT) - Ld. DR
Section 144CSection 144C(5)Section 147Section 148Section 148ASection 151ASection 69

upon perusal of case records, the appeal is disposed-off as under. Draft Assessment Order and Proceedings before Ld. DRP 3.1 The assessee being non-resident did not file its return of income. Pursuant to receipt of information that the assessee transacted in Bitcoins, a notice u/s 148A

M/S Regen Renewable Energy Generation Global Limited, Chennai vs. ACIT, International Taxation Circle - 2 (1), Chennai

The appeals stand allowed for statistical purposes

ITA 685/CHNY/2022[2015-2016]Status: DisposedITAT Chennai10 Jul 2024AY 2015-2016

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm 1. आयकरअपील सं./ Ita No.684/Chny/2022 (िनधा;रण वष; / Assessment Year: 2014-15) & 2. आयकरअपील सं./ Ita No.685/Chny/2022 (िनधा;रण वष; / Assessment Year: 2015-16) M/S Regen Renewable Energy Acit बनाम Generation Global Limited International Taxation New No.1, Pulla Avenue, / Vs. Circle-2(1), Chennai. Shenoy Nagar, Chennai-600 030. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafcr-0685-N (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Appellant By : Shri B. Ramakrishnan (Ca) – Ld.Ar " थ"कीओरसे/Respondent By : Mrs. Jyothi Lakshmi Nayak (Cit)-Ld. Dr सुनवाई की तारीख/Date Of Hearing : 03-06-2024 घोषणा की तारीख /Date Of Pronouncement : 10-07-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

For Appellant: Shri B. Ramakrishnan (CA) – Ld.ARFor Respondent: Mrs. Jyothi Lakshmi Nayak (CIT)-Ld. DR
Section 115A(1)(b)Section 143(3)Section 144CSection 144C(5)Section 147Section 148Section 153Section 234B

variation in the income or loss returned which is prejudicial to the interest of such assessee. The assessee before us is a non-resident company incorporated, and fiscally domiciled, in Cyprus. Accordingly, in terms of Section 144C(15)(b)(ii), the assessee is an eligible assessee but then there

M/S Regen Renewable Energy Generation Global Limited, Chennai vs. ACIT, International Taxation Circle - 2 (1), Chennai

The appeals stand allowed for statistical purposes

ITA 684/CHNY/2022[2014-2015]Status: DisposedITAT Chennai10 Jul 2024AY 2014-2015

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm 1. आयकरअपील सं./ Ita No.684/Chny/2022 (िनधा;रण वष; / Assessment Year: 2014-15) & 2. आयकरअपील सं./ Ita No.685/Chny/2022 (िनधा;रण वष; / Assessment Year: 2015-16) M/S Regen Renewable Energy Acit बनाम Generation Global Limited International Taxation New No.1, Pulla Avenue, / Vs. Circle-2(1), Chennai. Shenoy Nagar, Chennai-600 030. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafcr-0685-N (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Appellant By : Shri B. Ramakrishnan (Ca) – Ld.Ar " थ"कीओरसे/Respondent By : Mrs. Jyothi Lakshmi Nayak (Cit)-Ld. Dr सुनवाई की तारीख/Date Of Hearing : 03-06-2024 घोषणा की तारीख /Date Of Pronouncement : 10-07-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

For Appellant: Shri B. Ramakrishnan (CA) – Ld.ARFor Respondent: Mrs. Jyothi Lakshmi Nayak (CIT)-Ld. DR
Section 115A(1)(b)Section 143(3)Section 144CSection 144C(5)Section 147Section 148Section 153Section 234B

variation in the income or loss returned which is prejudicial to the interest of such assessee. The assessee before us is a non-resident company incorporated, and fiscally domiciled, in Cyprus. Accordingly, in terms of Section 144C(15)(b)(ii), the assessee is an eligible assessee but then there

Philips India Ltd, Kolkata vs. ACIT, Kolkata

In the result, all the appeals of the assessee are dismissed

ITA 341/KOL/2023[2019-20]Status: DisposedITAT Kolkata08 Jul 2024AY 2019-20

Bench: Dr. Manish Borad & Shri Pradip Kumar Choubeyi.T.A. Nos.338 To 341/Kol/2023 Assessment Years: 2016-17 To 2019-20 Philips India Ltd ………. Appellant (Pan: Aabcp9487A) Vs. Asstt. Commissioner Of Income Tax, Circle-12(2), Kolkata. ………… Respondent Appearances By: Shri Vishal Jain Ar Appeared For Appellant. Shri P. P. Barman, Addl. Cit, Sr. Dr Appeared For Respondent. Date Of Concluding The Hearing : 03.07.2024 Date Of Pronouncing The Order : 08.07.2024 Order Per Manish Borad: All These Captioned Appeals Filed By The Assessee Pertaining To The Assessment Years (In Short “Ay”) 2016-17 To 2019-20 Are Directed Against The Separate Orders Passed U/S 250 Of The Income Tax Act, 1961 (In Short The “Act”) By Ld. Commissioner Of Income-Tax, Appeal, National Faceless Appeal Centre (Nfac), Delhi [In Short Ld. “Cit(A)”] Dated 10.02.2023 Arising Out Of The Assessment Order U/S 237 Of The Act By Acit, Circle-12(2), Kolkata Dated 26.06.2019 (For Ays 2016-17, 2017-18 & 2019-20), 28.06.2019 (For Ay 2018-19) Respectively. Since Grounds Are Common & Facts Are Identical, Except Variance In Amount, We Dispose Of All The Appeals By This Consolidated Order

Section 115Section 237Section 244ASection 250

normal rate u/s. 115-O of the Act it is entitled to the excess DDT paid by it on the dividend distributed to non-resident shareholder namely, Koninklijke Philips N.V. We however, fail to find any merit in this ground of appeal of the assessee since similar issue has already ... Total Oil India Private Limited (supra), which reads as under:- “Where dividend is declared, distributed or paid by a domestic company to a non-resident shareholder(s), which attracts additional income- tax (tax on distributed profits) referred to in section 115-O of the Income Tax Act, 1961 (in short

Philips India Ltd, Kolkata vs. ACIT, Kolkata

In the result, all the appeals of the assessee are dismissed

ITA 340/KOL/2023[2018-19]Status: DisposedITAT Kolkata08 Jul 2024AY 2018-19

Bench: Dr. Manish Borad & Shri Pradip Kumar Choubeyi.T.A. Nos.338 To 341/Kol/2023 Assessment Years: 2016-17 To 2019-20 Philips India Ltd ………. Appellant (Pan: Aabcp9487A) Vs. Asstt. Commissioner Of Income Tax, Circle-12(2), Kolkata. ………… Respondent Appearances By: Shri Vishal Jain Ar Appeared For Appellant. Shri P. P. Barman, Addl. Cit, Sr. Dr Appeared For Respondent. Date Of Concluding The Hearing : 03.07.2024 Date Of Pronouncing The Order : 08.07.2024 Order Per Manish Borad: All These Captioned Appeals Filed By The Assessee Pertaining To The Assessment Years (In Short “Ay”) 2016-17 To 2019-20 Are Directed Against The Separate Orders Passed U/S 250 Of The Income Tax Act, 1961 (In Short The “Act”) By Ld. Commissioner Of Income-Tax, Appeal, National Faceless Appeal Centre (Nfac), Delhi [In Short Ld. “Cit(A)”] Dated 10.02.2023 Arising Out Of The Assessment Order U/S 237 Of The Act By Acit, Circle-12(2), Kolkata Dated 26.06.2019 (For Ays 2016-17, 2017-18 & 2019-20), 28.06.2019 (For Ay 2018-19) Respectively. Since Grounds Are Common & Facts Are Identical, Except Variance In Amount, We Dispose Of All The Appeals By This Consolidated Order

Section 115Section 237Section 244ASection 250

normal rate u/s. 115-O of the Act it is entitled to the excess DDT paid by it on the dividend distributed to non-resident shareholder namely, Koninklijke Philips N.V. We however, fail to find any merit in this ground of appeal of the assessee since similar issue has already ... Total Oil India Private Limited (supra), which reads as under:- “Where dividend is declared, distributed or paid by a domestic company to a non-resident shareholder(s), which attracts additional income- tax (tax on distributed profits) referred to in section 115-O of the Income Tax Act, 1961 (in short

Philips India Ltd, Kolkata vs. ACIT, Kolkata

In the result, all the appeals of the assessee are dismissed

ITA 339/KOL/2023[2017-18]Status: DisposedITAT Kolkata08 Jul 2024AY 2017-18

Bench: Dr. Manish Borad & Shri Pradip Kumar Choubeyi.T.A. Nos.338 To 341/Kol/2023 Assessment Years: 2016-17 To 2019-20 Philips India Ltd ………. Appellant (Pan: Aabcp9487A) Vs. Asstt. Commissioner Of Income Tax, Circle-12(2), Kolkata. ………… Respondent Appearances By: Shri Vishal Jain Ar Appeared For Appellant. Shri P. P. Barman, Addl. Cit, Sr. Dr Appeared For Respondent. Date Of Concluding The Hearing : 03.07.2024 Date Of Pronouncing The Order : 08.07.2024 Order Per Manish Borad: All These Captioned Appeals Filed By The Assessee Pertaining To The Assessment Years (In Short “Ay”) 2016-17 To 2019-20 Are Directed Against The Separate Orders Passed U/S 250 Of The Income Tax Act, 1961 (In Short The “Act”) By Ld. Commissioner Of Income-Tax, Appeal, National Faceless Appeal Centre (Nfac), Delhi [In Short Ld. “Cit(A)”] Dated 10.02.2023 Arising Out Of The Assessment Order U/S 237 Of The Act By Acit, Circle-12(2), Kolkata Dated 26.06.2019 (For Ays 2016-17, 2017-18 & 2019-20), 28.06.2019 (For Ay 2018-19) Respectively. Since Grounds Are Common & Facts Are Identical, Except Variance In Amount, We Dispose Of All The Appeals By This Consolidated Order

Section 115Section 237Section 244ASection 250

normal rate u/s. 115-O of the Act it is entitled to the excess DDT paid by it on the dividend distributed to non-resident shareholder namely, Koninklijke Philips N.V. We however, fail to find any merit in this ground of appeal of the assessee since similar issue has already ... Total Oil India Private Limited (supra), which reads as under:- “Where dividend is declared, distributed or paid by a domestic company to a non-resident shareholder(s), which attracts additional income- tax (tax on distributed profits) referred to in section 115-O of the Income Tax Act, 1961 (in short

Philips India Ltd, Kolkata vs. ACIT, Kolkata

In the result, all the appeals of the assessee are dismissed

ITA 338/KOL/2023[2016-17]Status: DisposedITAT Kolkata08 Jul 2024AY 2016-17

Bench: Dr. Manish Borad & Shri Pradip Kumar Choubeyi.T.A. Nos.338 To 341/Kol/2023 Assessment Years: 2016-17 To 2019-20 Philips India Ltd ………. Appellant (Pan: Aabcp9487A) Vs. Asstt. Commissioner Of Income Tax, Circle-12(2), Kolkata. ………… Respondent Appearances By: Shri Vishal Jain Ar Appeared For Appellant. Shri P. P. Barman, Addl. Cit, Sr. Dr Appeared For Respondent. Date Of Concluding The Hearing : 03.07.2024 Date Of Pronouncing The Order : 08.07.2024 Order Per Manish Borad: All These Captioned Appeals Filed By The Assessee Pertaining To The Assessment Years (In Short “Ay”) 2016-17 To 2019-20 Are Directed Against The Separate Orders Passed U/S 250 Of The Income Tax Act, 1961 (In Short The “Act”) By Ld. Commissioner Of Income-Tax, Appeal, National Faceless Appeal Centre (Nfac), Delhi [In Short Ld. “Cit(A)”] Dated 10.02.2023 Arising Out Of The Assessment Order U/S 237 Of The Act By Acit, Circle-12(2), Kolkata Dated 26.06.2019 (For Ays 2016-17, 2017-18 & 2019-20), 28.06.2019 (For Ay 2018-19) Respectively. Since Grounds Are Common & Facts Are Identical, Except Variance In Amount, We Dispose Of All The Appeals By This Consolidated Order

Section 115Section 237Section 244ASection 250

normal rate u/s. 115-O of the Act it is entitled to the excess DDT paid by it on the dividend distributed to non-resident shareholder namely, Koninklijke Philips N.V. We however, fail to find any merit in this ground of appeal of the assessee since similar issue has already ... Total Oil India Private Limited (supra), which reads as under:- “Where dividend is declared, distributed or paid by a domestic company to a non-resident shareholder(s), which attracts additional income- tax (tax on distributed profits) referred to in section 115-O of the Income Tax Act, 1961 (in short