AAR admitted application to decide taxability of sum received in relation to offshore supplies from a port in Japan

INCOME TAX : Applicant filed an application for advance ruling on whether amount received/receivable by applicant from DMRC under purchase order in relation to offshore supplies of High Efficiency Traction Motors for RS-1 from a port in Japan to DMRC in India, is liable to tax in India under provisions of Act and/or the agreement for Avoidance of Double Taxation between India and Japan(Treaty). Revenue submitted that transaction was designed prima facie for avoidance of tax

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