ISHIKAWAJMA-HARIMA HEAVY INDUSTRIES LTD. vs. DIRECTOR OF INCOME TAX, MUMBAI
The appeal is allowed in part and to
C.A. No.-000009-000009 - 2007Supreme Court04 Jan 2007
For Respondent: Director of Income Tax, Mumbai
Section 241
viii) Supply of goods whether offshore or onshore as well as
rendition of service whether offshore or onshore are attributable to the
turnkey project and, thus, it would be wrong to contend that in terms of
Article 7 of DTAA, no tax could be levied upon the appellant.
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