Supreme Court of India
Ishikawajma-harima Heavy Industries Ltd. v. Director of Income Tax, Mumbai
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1 Supreme Court bench has cited this judgment.
From the 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 foreign company entering into a contract with an Indian company for offshore supply of equipments and providing services-Tax liability- Extent of-Held: Contract executed in India-Since part thereof has to be carried 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 Act-Income arising out of
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