Supreme Court · 2007 INSC 633 · Decided 18 May 2007

Commissioner of Income Tax, Meerut and ANR. v. M/S. Hyundai Heavy Industries CO. LTD

Court
Supreme Court of India
Citation
2007 INSC 633 · [2007] 7 S.C.R. 288
Case number
CIVIL APPEAL No. 2734/2007
Decided
18 May 2007
Bench
S.H. KAPADIA, B. SUDERSHAN REDDY (2-judge bench)
Outcome
Case Partly allowed
Case type
Civil
Acts & sections cited
Income Tax Act Section 9, 44BB, 143(2), 144, 9(1)

Headnote

OF INCOME TAX, MEER.UT AND ANR. · . ,· ' MIS. HYUNDAI HEAVY INDUSTRIES CO. LID ... MAY 18,2007 B [SR KAPADIA AND B. SUDERSHAN REDDY, JJ.l · Income Tax Act, 1961-Sections 9, 44BB, 143 (2) & 144-Convetition for Avoidance of Double Taxation-Article 7-Contract entered that the contract is divisible into Indian operatio~ and foreign opera#om; · that income from Indian operations is not liable to tax as it did not have Permanent Establishment in India; and that the inco,,,e froni foreign operations. is not D liable to tax·.as. it is earned

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