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Director of Income Tax (International Taxation) Versus Toyo Engineering Corporation

2013 (1) TMI 936 - BOMBAY HIGH COURT

Income Tax Appeal No. 663 of 2011 - Dated:- 23-1-2013 - J. P. Devadhar And M. S. Sanklecha, JJ. For the Appellant : Tejveer Singh with Suresh Kumar For the Respondent : Madhur Agarwal i/by Mint & Confreres ORDER 1. In this appeal by the Revenue f .....

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upply contract to MRPL cannot be taxed in India under the provision of Section 9 of the Income Tax Act, 1961 ? b) Whether, on the facts and circumstances of the case, the Tribunal was correct in law in holding that Assessing Officer should have compu .....

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l in the impugned order while holding that income arising from contract of offshore supply of equipment cannot be brought to tax in India as the same has not accrued or arisen in India, reliance was placed upon its own decision in the matters of Siem .....

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No.1033 of 2011 (Siemens Aktiengesellschaft) and in Income Tax Appeal No.825 of 2010 (M/s.Xelo Pty. Limited), were dismissed by this Court on 20th November 2012 and 15th November 2011 respectively. Therefore, according to the respondent-assessee ques .....

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mine whether the equipments and materials were supplied outside India or in India. This is not correct as the Tribunal in para26 of the impugned order has recorded a finding of fact that on examination of the clauses of the contract the supply of equ .....

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articularly the decisions of this Court in the matters of M/s.Xelo Pty. Limited (supra) and Siemens Aktiengesellschaft (supra), question (a) as proposed cannot be entertained. 3. So far as question (b) is concerned, both the Commissioner of Income Ta .....

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