Turnkey contract can be splitted & only Profit attributable to PE in India is liable to tax

IN THE ITAT DELHI BENCH ‘E’ National Petroleum Construction Company versus Additional Director of Income-tax – (International Taxation) IT APPEAL NO. 5168 (DELHI) OF 2010 [ASSESSMENT YEAR 2007-08] October 5, 2012 ORDER Shamim Yahya, Accountant Member   This appeal by the Assessee is directed against the order of the Assessing Officer dated 26.10.2010 pertaining to assessment year 2007-08 passed under section 143(3)/144 of the I.T. Act, 1961. 2. The grounds raised read as under:-  1.  That the learned (‘Ld’) Assessing Officer (‘AO’) ...