ACIT, CIRCLE- 2, INTERNATIONAL TAXATION, DEHRADUN vs. SOLAR TURBINES INTERNATIONAL CO., BENGALURU
In the result, the appeal of the Revenue is dismissed
ITA 441/DEL/2018[2013-14]Status: DisposedITAT Dehradun29 Apr 2022AY 2013-14
Bench: Dr. B.R.R. Kumar & Sh. Yogesh Kumar U.S.Assessment Year: 2014-15 Solar Turbines International Vs Dcit, Company (Singapore Branch Of Circle-2, Solar Turbines International International Taxation, Company, Usa), Dehradun. 14 Tractor Road, Singapore, C/O Delloitte Haskins & Sells Llp, Deloitte Centre Anchorage- Ii, Richmond Road, Bangalore. (Appellant) (Respondent) Pan No. Aajcs3585J Assessment Year: 2014-15
For Appellant: NoneFor Respondent: Shri T.S. Mapwal, Sr.DR
Section 2(43)Section 40Section 43BSection 90(2)
transferred outside India before it reaches the / premise of the buyer in India. Payments were made through irrevocable letter of credit / and the buyer SI group Ltd is an independent and unrelated party and purchased the equipment from the appellant company on its own account. The purchase order was placed on a principle to principle basis.
21. In view