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2011 (2) TMI 119 - AAR - Income TaxDTAA - International transaction - Presumptive rate of taxation under section 44BBB - Held that: - whether the consideration received by the Applicant for the steam turbine, turbo generator erection of auxiliaries, other equipments including associated electrical, instrumentation and pre-commissioning work for the five units of 800 MW each of Ultra Mega Power Project at Mundra (“Mundra UMP project”), Gujarat is eligible for presumptive rate of taxation under section 44BBB of the Act in India. - Held Yes. if the Applicant engages the services of a related party or third party for supply of labour for executing the work under the contract with the condition that the overall responsibility would remain with the Applicant, whether the Applicant would be eligible for presumptive rate of taxation under section 44BBB of the Act on the entire consideration receivable in terms of the contract - Held Yes.
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