Supreme Court · 2007 INSC 2 · Decided 4 January 2007
Ishikawajma-Harima Heavy Industries LTD. v. Director of Income Tax, Mumbai
- Court
- Supreme Court of India
- Citation
- 2007 INSC 2 · [2007] 1 S.C.R. 112
- Case number
- CIVIL APPEAL No. 9/2007
- Decided
- 4 January 2007
- Bench
- S.B. SINHA, DALVEER BHANDARI (2-judge bench)
- Outcome
- Case Partly allowed
- Case type
- Civil
- Acts & sections cited
- Income Tax Act Section 241(Q)(l), 9
Headnote
income TaxAct, 1961; ss. 5, 9, 42 and 24I(q)(J) of Double Taxation Avoidance Agreement, Clauses 5 and 7, Article I 2: income tax liability­ A foreign company entering into a contract with an Indian company for C offshore supply of equipments and providing services-Tax liability-­ Extent out outside India, entire income derived by Contractor would not be taxable in India-Income arising from a business connection could be assessed keeping into consideration terms of the agreement and s.9 of the D Act-Income arising out of operation in more than one jurisdiction would have
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