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2012 (11) TMI 307 - ITAT DELHITaxability – offshore supply - foreign company was engaged in the execution of various projects in India - company has executed five contracts - For the purpose of executing the five contracts mentioned above, LGCL had set up a project office in India - It was also claimed by the assessee during the assessment proceedings that the “Power Grid Corporation of India Limited (PGCIL) imported certain materials from LGCL, Korea - PGCIL deducted tax at source while making payments to LGCL – Held that:- There were no operation qua the agreement for supply of equipment, which was carried out in India, and therefore, no income could be deemed to have accrued or arisen in India whether directly or indirectly or through any business connection in India - credit of TDS deducted allowed - in favour of the assessee
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