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ITAT allowed the taxpayer's appeal, reversing the CIT(IT)'s revision order under Section 263. The tribunal held that offshore revenues from equipment sales originating in China were not taxable in India, consistent with Supreme Court precedents in Hyundai Heavy Industries and Ishikawajima Harima Heavy Industries cases. The tribunal determined that the revenue department erroneously clubbed offshore and onshore revenues and unilaterally redrew contractual clauses. Consequently, the offshore supplies were deemed non-taxable under normal provisions, and Section 44BBE was also found inapplicable. The decision ultimately favored the assessee and rejected the department's taxation claims.
ITAT allowed the taxpayer's appeal, reversing the CIT(IT)'s revision order under Section 263. The tribunal held that offshore revenues from equipment sales originating in China were not taxable in India, consistent with Supreme Court precedents in Hyundai Heavy Industries and Ishikawajima Harima Heavy Industries cases. The tribunal determined that the revenue department erroneously clubbed offshore and onshore revenues and unilaterally redrew contractual clauses. Consequently, the offshore supplies were deemed non-taxable under normal provisions, and Section 44BBE was also found inapplicable. The decision ultimately favored the assessee and rejected the department's taxation claims.
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