Income attributable to activities carried out outside India is not taxable in India

Brief of the Case

ITAT Delhi held In the case of Hyundai Heavy Industries Co. Ltd. vs. ADIT that the said issue is already covered in favour of the assessee by tribunal decision given in earlier years in which the tribunal held that the contracts are divisible. The receipts pertaining to designing, fabrication and supply of material, the activities carried out outside India is not taxable in India. It is a well established proposition of law that the authorities below have to follow the decision

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