The Tax Publishers2006 TaxPub(DT) 0571 (Uttarakhand-HC) : (2006) 010 (I) ITCL 0205 : (2006) 279 ITR 0001 : (2005) 198 CTR 0364 : (2005) 147 TAXMAN 0389

Sedco Forex International v. CIT, Dehradun

INCOME TAX ACT, 1961

Double taxation relief - Agreement between India and UK -Chargeability

Held: To avail benefit under DTAA between India and UK, an assessee, a non-resident-citizen, had to prove that remuneration received by him for services rendered in India was chargeable to tax in other Contracting State of which he was resident.

Income-tax Act, 1961, Section 90

A.Y. :1989-90 and 1990-91
Decision: In favour of revenue.

Sedco Forex International v. CIT, Dehradun

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