Receipt for offshore supply of equipment, plants by foreign company not taxable in India: ITAT Delhi

SMS Group Gmbh Vs ACIT (ITAT Delhi) ITAT Delhi held that foreign company receiving consideration for offshore supply of equipment, plant, designs and drawings is not taxable in India since entire transaction has taken place outside India. Facts- The assessee is a tax resident of Germany, engaged in a business of supply of plants & equipments, supply of drawings and designs and rendering supervisory services in erection, commissioning, performance guarantee, test of equipment supply; and rendering technical services to the customers in metallurgical sector in various parts of the country....