2016 (11) TMI 1496

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..... s on sale of Off-shore supply of equipments should be treated to have accrued in India and profit in this respect should be determined on the basis of Global Profit Ratio - Held that:- The Tribunal has arrived at the above decision, which has been confirmed by Hon'ble Apex Court in the case of Ishikawajma-Harima Heavy Industries Ltd. vs. Director of Income Tax, Mumbai (2007 (1) TMI 91 - SUPREME CO .....

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..... lant :- Dhananjay Awasthi For the Respondent : Gaurav Mahajan ORDER Heard Sri Manish Goel, learned Counsel for the department and Sri M.P. Rastogi, learned Counsel for the assessee This is an appeal filed by the department under Section 260A of the Income Tax Act, 1961 against the order of the Tribunal dated 12.05.2006 for the assessment year 2002-03. The question of law sought to be answered .....

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..... a divisible contract and for the manufacturing part it was not liable to pay any taxes in India as there was no element of sale at all in India. On facts it has not been recorded anywhere on the record that the situs of sale of the manufactured items took place in India. The entire equipment required by the Gas and Oil Company was completely manufactured outside India and it is only the installati .....

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