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2011 (4) TMI 441 - HC - Income TaxReopening - DTAA between India and France - Onshore supply, Onshore services and Offshore supply - TDS u/s 195 - It is asserted that PGCIL, a public sector company, had awarded a turnkey project to Areva T&D SA, the petitioner herein, and it was responsible for completing the offshore supply, onshore supply and onshore services contracts - As the installation and assembly projects continued for a period of more than 6 months in all the 4 contracts, therefore, the assessee had construction PE also in India - assessee has always obtained orders under section 197 of the Act without disclosing the full facts relating to the contracts, some of these facts are discussed in these reasons and assessee has not filed its return of income for any of the assessment years - Initiation of proceedings u/s 147 upheld.
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