Case Law Details
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 by the National Thermal Power Corporation (NTPC), the applicant successfully bid the tender and three separate following contracts are entered into with the NTPC: 1.(1) Offshore supply contract – Contract No. CS-9558-102- 2-FC-COA- 4520 dated 25.3.2005. (`Offshore supply contract No. 4520) for design, engineering, manufacture, inspection and testing at supplier’s works, packing, forwarding and dispatch from manufacturer’ s works to the port of disembarkation in India of all offshore plant & equipment including mandatory spares.
(2) Onshore supply contract – Contract No. CS-9558-102- 2-SC-COA- 4521 dated 25.3.2005.
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