2019 (6) TMI 1224

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....learned counsel on both sides, the main writ petition itself is taken up, heard out and is being disposed of. 3.The entire matter turns on a very narrow compass. 4. Writ petitioner is a foreign company incorporated under the laws of Singapore and therefore a tax resident of Singapore. Petitioner company is engaged in the business of heavy lifting, erection and primarily carries out work relating to various refineries projects in several countries in Asia and in the Gulf region. 5. Under the aforesaid circumstances, writ petitioner filed three different applications before Authority for Advance Ruling seeking its ruling in respect of three different projects undertaken by the writ petitioner and query for which ruling from the '....

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.... LIST OF DATES S.No. Date Particulars 1 01.04.2013 to 31.03.2014 Previous Year relevant to Assessment Year 2014-15 2 11.04.2014 Applications filed before Authority for Advance Ruling in respect of the Projects viz., (1) Larsen & Toubro, Punjab and (2) Punj Lloyd Ltd., Karnataka 3 13.06.2014 Application field before Authority for Advance Ruling in respect of the project viz., GR Engineering Pvt. Ltd., 4 30.11.2014 Due date for Return for AY.2014-15 5 16.08.2016 Authority for Advance Ruling pronounced Ruling-Income to be computed u/s.44BB of Income Tax Act, 1961 6 06.03.2017 Return filed claiming refund Rs. 9,33,290/- 7 16.03.2017 Petition u/s.119(2)(b) for Condoning of D....