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2011 (7) TMI 99 - AAR - Income TaxAdvance ruling - Consortium agreement - Application u/s 245R(2) - Taxability of the off-shore sales by LS Cables to the applicant - Applicant transfer the goods by LS Cables, Korea to the applicant being outside India, there is no territorial nexus for taxation regarding those off-shore supplies - It is pointed out that the applicant after obtaining the goods from LS Cables, Korea sells them to KPTCL for consideration - For its on-shore activity, including the sale it is taxed in India. Learned Counsel specifically requested as to note that sale by the applicant to KPTCL is taxed in India since it is taxable in India and that part of the contract is not involved in this application - It is submitted that in the light of the decision of the Supreme Court in Ishikawajima Harima Heavy Industries V/s DIT [2007 (1) TMI 91 - SUPREME COURT ], the questions raised by the applicant have to be ruled in favour of the applicant - Decided in favour of assessee.
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