Income earned from offshore supply not taxable in India as none of operation is carried out in India

Schindler China Elevator Company Ltd Vs ACIT (ITAT Mumbai) ITAT Mumbai held that income earned from offshore supply of escalators and elevators is not taxable in India as assesse didn’t carried out any operations in India. Facts- The assessee is a non-resident company incorporated in China and is engaged in the business of supply of elevators and escalators, which includes design and manufacturing. During the year under consideration, the assessee considered receipts of Rs.17,42,55,454 from Delhi Metro Rail Corporation Ltd (DMRCL) and Rs. 2,80,74,219 from Maharashtra Metro Rail Corporation L...