https://www.taxtmi.com/caselaws?id=213866 The Authority held that the contract between the Consortium and BMRC was indivisible, and the entire income from the contract, including offshore services, was taxable in India. The members of the Consortium were deemed to have formed an Association of Persons (AOP) based on their joint actions and common purpose in executing the project. The decision was influenced by the holistic approach mandated by the Supreme Court in Vodafone International Holdings BV v. UOI, emphasizing the entirety of the transaction for tax assessment purposes. en-us Thu, 07 Jun 2012 00:00:00 +0530 Fri, 25 Jan 2013 13:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=213866 The Authority held that the contract between the Consortium and BMRC was indivisible, and the entire income from the contract, including offshore services, was taxable in India. The members of the Consortium were deemed to have formed an Association of Persons (AOP) based on their joint actions and common purpose in executing the project. The decision was influenced by the holistic approach mandated by the Supreme Court in Vodafone International Holdings BV v. UOI, emphasizing the entirety of the transaction for tax assessment purposes. Case-Laws Income Tax Thu, 07 Jun 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=213866