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
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 has earned