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Offshore supply of equipment for setting up petro plant in India not taxable in India

February 18, 2021[2021] 124 389 (AAR - New Delhi)

INTERNATIONAL TAXATION : Indian Petro company OPAL desired to setup Butene-1 Plant on a lump-sum turnkey basis - Contract was awarded to applicant-French company under which plant was to setup using proprietary technology owned by another French company being an international provider of established technology to hydrocarbon industry - Held, that consideration received by applicant-French company from OPAL for offshore supply of equipments is not chargeable to tax in India - Consideration received in respect of basic engineering design services in relation to construction, erection, installation, commissioning and testing of plant and advisory services in relation to detailed engineering are liable to tax in India as business income of PE of applicant

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