TMI Blog2021 (3) TMI 333X X X X Extracts X X X X X X X X Extracts X X X X ..... ment for Avoidance of Double Taxation between India and Japan ('the Treaty') - only objection of the Revenue is that the transaction was designed prima-facie for avoidance of tax - CIT has contended that there was a business connection of the applicant in India which constitutes Permanent Establishment and an appropriate profit needs to be attributable to the P.E. in India. Therefore, the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... x. Therefore, the application is admitted u/s 245 R (2) of the Act. - AAR/NCR/20/2020 - - - Dated:- 12-1-2021 - Narendra Prasad Sinha, Chairman and Ramayan Yadav, Member (Law) Kanchan Kashal for the Applicant. Anurag Prasad and Smt. Radha Katyal Narang for the Respondent. ORDER We have heard both the parties. The applicant has filed the present application on 24/11/2020 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... IT has pointed out that the applicant was responsible for care and custody together with the risk of loss or damage of the equipments of offshore supply till they were delivered to DMRC depot in Delhi. It is further pointed out that the custom duty, insurance etc; was also the liability of the applicant. The CIT has contended that there was a business connection of the applicant in India which con ..... X X X X Extracts X X X X X X X X Extracts X X X X
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