https://www.taxtmi.com/caselaws?id=76511 The Authority ruled in favor of the applicant, a Russian company, stating that no tax liability exists under the Income-tax Act or the India-Russia DTAA for amounts received from NTPC under the offshore supply contract. The decision was based on the completion of the transaction outside India, property transfer on high seas, and payment receipt outside India. The ruling aligned with the Supreme Court precedent in Ishikawajma, rejecting Revenue's arguments on contract classification and Permanent Establishment existence. en-us Thu, 25 Feb 2010 00:00:00 +0530 Tue, 06 Sep 2011 18:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=76511 The Authority ruled in favor of the applicant, a Russian company, stating that no tax liability exists under the Income-tax Act or the India-Russia DTAA for amounts received from NTPC under the offshore supply contract. The decision was based on the completion of the transaction outside India, property transfer on high seas, and payment receipt outside India. The ruling aligned with the Supreme Court precedent in Ishikawajma, rejecting Revenue's arguments on contract classification and Permanent Establishment existence. Case-Laws Income Tax Thu, 25 Feb 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=76511