ITAT lay down principles on ‘splitting of turnkey contracts’, role of PE and taxability of profits from offshore supply

Samsung Heavy Industries Co. Ltd. Vs ADIT (International Taxation)- It is held that the turnkey contract is not divisible and therefore, the offshore supply and offshore services can be attributed to the Indian permanent establishment; as the project office was opened for coordination and execution of project, the same is held to be a fixed place PE.

Whether assessee’s arguments that all the activities carried out by the project office till the complet

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