Consortium formed by non-residents for bidding for a turnkey contract taxable as AOP

Looking at’ the nature of transaction, consortium bidding & executing turnkey project taxable as AOP, contract cannot be dissected for tax purposes -AAR AAR held that a consortium formed by the Applicant with another non-resident, to bid for a turnkey contract, is liable to be taxed as Association of Persons (AOP) according to the Income-tax Act, 1961 (the Act) and the Double Tax Avoidance Agreement (tax treaty) between India and Germany. The AAR also held that an internal division of responsibility between consortium members does not alter the formation of an AOP and indivisible nat...