Services provided for purchase of goods to be exported from India may not be eligible for exemption provided under Income-tax provisions

Facts

• The applicant, Aramco Overseas Company (AOC) is a Dutch tax resident company. It is a subsidiary of Saudi Arabian Oil Company (Saudi AramCo). AOC provides services in relation to supply chain management, technical support, finance support and administrative support to its holding company and other group companies. For such services, AOC gets remuneration on cost plus 5 percent basis.
• AOC is proposing to set up an office in India to undertake procurement support activities. The Indian offic

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