OUTOTEC(FINLAND) OY (NOW MERGED WITH "METSO MINERALS OY" AND THE MERGED ENTITY HAS BEEN RENAMED TO METSO OUTOTEC FINLAND OY),GURUGRAM vs. DCIT(INTERNATIONAL TAXATION), CIRCLE-2(1), KOLKATA, KOLKATA
In the result,both the appeals of the assessee are partly allowed
ITA 350/KOL/2022[2018-2019]Status: DisposedITAT Kolkata28 Feb 2023AY 2018-2019
Bench: Shri Rajpal Yadav & Shri Girish Agrawal
For Appellant: Shri K. M. Gupta, ARFor Respondent: Shri G. HukughaSema, CIT, DR
Section 143(3)Section 144C(13)Section 144C(5)Section 270ASection 271A
271A and 271B of the Act.
3. Brief facts of the case are that assessee is incorporated in Finland and is a tax resident of the same. Assessee is a worldwide leader in providing innovative and environmentally sound solutions for a wide range of customers in metals processing industries. During the year under consideration, with regard to Indian projects, assessee