Home Case Index All Cases Income Tax Income Tax + HC Income Tax - 2013 (1) TMI HC This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2013 (1) TMI 477 - HC - Income TaxAddition taking recourse to Special provision for computing profits and gains in connection with the business of exploration, etc., of mineral oils - nexus between the services rendered in India and administrative and support services provided outside India Agreement No. 70711 entered during the period of fabrication, outfitting and manufacturing of load out platform for Tapti and Panna field development - Held that:- Merely because the agreement in question was entered at the time when the fabrication activity for Tapti and Panna was going on, it could not be contended that the agreement related or the subject matter thereof was for the fabrication of Tapti and Panna field development. As aforesaid, independently also, it could not be established that the said agreement had any nexus with the activities for construction of Tapti and Panna field development. That being the situation, income derived from the said agreement, entered outside India, for providing administrative and support services outside India and, in respect whereof, remuneration has been received outside India, will not come within Section 5(2) r.w.s.9(1)(i) accordingly, is not taxable in India.
|