Income-tax Authorities have no jurisdiction to tax payment made outside for supplies taking place outside the country

In Re SEPCO III Electric Power Construction (AAR) – The applicant is a company incorporated under the laws of China on 26.3.2009. The applicant, among other things, is a supplier of equipments for Electric Power Projects. On 26.3.2009, the applicant entered into a contract with M/s Jhajjar Power Limited, for supplying of equipments for the Haryana Power Project. That contract was amended and restated on 1.6.2009. According to the applicant, it is an off-shore supply contract requiring the applicant to carryout design, engineering, procuring and transportation to the port of loading of t...