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2011 (9) TMI 482 - HC - Income TaxIncome deemed to accrue or arise in India - Foreign Co. engaged in the business of manufacture and sale of power transmission cable and related equipments entered into off-shore supply and on-shore erection testing, commissioning, etc. of Fiber Optic Cabling System for power transmission in different geographical regions of India - For Indian operation tax were paid and not for foreign - For Indian operation "only" assessee had appointed agents - AO and CIT(A) argued Income for both On shore - Of shore agreements have accrued in India and contract is a "Composite" one - Held That:- Tribunal is correct in holding "Stipulation in the on-shore contact relating to certain performances by the assessee including port handling, customs clearance, transportation, insurance, handling on site, unloading at transportation site, testing and commission to the satisfaction of the buyer are under a separate agreement for a separate consideration". No substantial question of law.
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