Whether the amount paid/payable by the Applicant to LSCL under the transaction mentioned in Annexure III in respect of Offshore supply of Equipments is liable to tax in India in the hands of LSCL, i.e. the recipient non-resident Korean company?

Deepak Cables (India) Limited Vs. DIT (International Taxation), Bangalore (Advance Ruling Authority)- It is the case of the applicant that transfer of the goods by LS Cables, Korea to the applicant being outside India, there is no territorial nexus for taxation regarding those off-shore supplies. It is pointed out that the applicant after obtaining the goods from LS Cables, Korea sells them to KPTCL for consideration. For its on-shore activity, including the sale it is taxed in India. Learned Counsel specifically requested as to note that sale by the applicant to KPTCL is taxed in India since...