Offshore supply of equipment not taxable in India hence section 44BBB wouldn’t apply

Shenhzhen SDG Information Co. Ltd. Vs CIT (ITAT Delhi) ITAT Delhi held that offshore supply of equipment revenue couldn’t be taxed in India. Thus, once it is not assessable even under the normal provisions, section 44BBB would also not apply. Accordingly, appeal allowed. Facts- Vide the present appeal, the appellant has mainly contested wrong invocation of provisions of section 263 of the Income Tax Act. Further, appellant has also contested wrong invocation of provisions of section 44BBB of the Income Tax Act whilst determining taxable income the appellant to be Rs. 6,43,77,612/- i.e. 10% o...