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2010 (9) TMI 624 - ITAT, DELHIDTAA between India and Italy - Carry forward and set off of business loss - Turn key contract - assessee company, which is a company incorporated in Italy, was awarded a turn key contract by IOCL, in November, 1999, for the designing, construction and commissioning of a Hydro-treater and Hydrogen facility at IOCL’s Guwahati Refinery - whether a contract is a composite/turn-key contract is not of much significance for determining the taxability of off-shore supply under the provisions of the Income-tax Act - off-shore supply revenue was taxable in India as per clause (1)(b) of Article 7 of the DTAA between India and Italy - in the case of Ishikawajima-Harima Heavy Industries Co. Ltd., In re [2004 (10) TMI 87 - AUTHORITY FOR ADVANCE RULINGS) - Held that: the offshore supply transaction was not taxable in India - Decided in the fvour of assessee
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