No Tax on off–shore supplies of goods completed outside Indian territory

Contract of sale in relation to the off– shore supplies having completed outside the territory of India and title to the goods having passed to the customer outside India, the amount received towards off–shore supply is not taxable in India. The issue in dispute in the aforesaid appeal is in relation to the decision of the Departmental Authorities in bringing to tax the receipt from off–shore supply of material and equipment. Brief facts are, the assessee a South Korean Company entered into contracts with Mumbai Railway Vikas Corporation (MRVC), Delhi Metro Rail Corp. (DMRC) as w...