2 July 2010,Friday Kapil Goel B.Com(H) FCA LLB Advocate Delhi ...

[2010] 3 taxmann.com 10(AAR - New Delhi)“Technopromexport”,• On the facts and circumstances of the case, whether the amountsreceived/receivable by Joint Stock Company Foreign EconomicAssociation “Technopromexport” (‘Applicant’ or ‘JSCTechnopromexport’) from National Thermal Power CorporationLimited (‘NTPC’) under Contract No. CS-9558-102-2-FC-COA-4520 dated 25 March 2005 (‘Offshore supply contract no. 4520’), forOffshore supply of all plant and equipment including mandatoryspares are liable to tax in India under the provisions of the IncometaxAct, 1961 (Act) and the 2.Agreement for Avoidance of DoubleTaxation between India and Russia (‘India-Russia tax treaty’)?