M/S. DEVICE DRIVEN (INDIA) PVT. LTD. vs. THE COMMISSIONER OF INCOME TAX
ITA/257/2014HC Kerala13 Oct 2020
Bench: HONOURABLE MR.JUSTICE K.VINOD CHANDRAN,HONOURABLE MR. JUSTICE T.R.RAVI
Section 10ASection 10BSection 143(1)Section 195Section 40Section 9(1)(vii)
125 ITR 525
(SC)] is relied on. It is pointed out that the activity of
the non-resident for which he was paid the commission was
entirely outside India and the income had no territorial
nexus with India, as has been held in Ishikawajima
- Harima
Heavy Industries v. Director of I.T. [(2007) 288 ITR 408
(SC)]. Though an explanation
