2015 (9) TMI 863 - SCH - Income Tax

Income u/s 5(2) - Income deemed to accrue or arisen in India u/s 9 - Part of business done in India - whether assessee purchases the goods for the purpose of exports, hence not liable to tax - Held that - Assessee is not carrying any business in India. They have established a liaison office. The activities of the assessee in assisting the Indian manufacturer to manufacture the goods according to their specification is to see that the said goods manufactured has an international market, therefore, it could be exported. In the process, the assessee is not earning any income in India. If at all he is earning income outside India under a contract which is entered outside India, no part of their income could be taxed in India either under Section 5 or Section 9 of the Act. - HC decision upheld 2013 (8) TMI 194 - KARNATAKA HIGH COURT - SC dismissed the revenue appeal.

Summary

The Supreme Court dismissed the special leave petitions after condoning the delay. Key personnel involved were Mr. Anil R. Dave, Mr. S.A. Bobde, Mr. Mohan Parasaran, Mr. D.L. Chidananda, Ms. A. Subhashini, and Mrs. Anil Katiyar.