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Composite contract cannot be split to exempt profits from offshore supply of goods
Case Law Details
- Case Name
- Mr. N. Venkatraman, Sr.Counsel Vs Director of Income Tax (Authority of Advance Rullings of Delhi (Income Tax)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- AAR Delhi, Advance Rulings
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What was the purpose for which the tender was invited by BMRC cannot be in doubt in this case. It was for installing the signaling and communication system for the metro rail. It was not for supply of offshore equipments independently of the installation and commissioning. Nor was it for independent installation and commissioning, divorced from the design and supply of the equipments necessary. Such a contract has necessarily to be read as a whole and is not capable of being split up.
On reading the contract in the context of the tender floated and the purpose sought to be a...
