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

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