If transaction for sale concluded outside India then no income from offshore supplies accrues or arises or can be deemed to accrue or arise in India

ADVANCE RULING DETAILS DECIDED BY: AUTHORITY FOR ADVANCE RULINGS (INCOME- TAX), NEW DELHI, ADVANCE RULING REQUESTED BY: Joint Stock Company Foreign Economic Association “Technopromexport”,  AAR No. 827 of 2009,  DECIDED ON: February 25, 2010 RELEVANT PARAGRAPH The applicant is a company incorporated in Russia and also is tax resident of that country. It is one of the leading companies in the field of power project construction and export of electric power and is further engaged in the business of construction and commissioning of power project. In response to the tender floated b...