IT/ILT : Where assessee rendered services as senior drilling engineer at Nigeria to an Indian company, fees was received by assessee in foreign currency for rendering said services outside India could not be brought to tax in India
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[2015] 55 taxmann.com 484 (Hyderabad - Trib.)
IN THE ITAT HYDERABAD BENCH 'A'
Income-tax Officer (International Taxation)-I, Hyderabad
v.
Janardhan Pannir*
P.M. JAGTAP, ACCOUNTANT MEMBER
AND SMT. ASHA VIJAYARAGHAVAN, JUDICIAL MEMBER
IT APPEAL NO. 721 (HYD.) OF 2014
[ASSESSMENT YEAR 2010-11]
DECEMBER 24, 2014
Section 9 of the Income-tax Act, 1961 - Income - Deemed to accrue or arise in India (Fee for technical services) - Assessment year 2010-11 - Whether where assessee was working as consultant-cum-independent contractor in order to render services as senior drilling/operation engineer at Nigeria (outside India) to an Indian company, amount received by assessee in foreign currency for rendering said services outside India could not be brought to tax in India - Held, yes [Para 14] [In favour of assessee]
■■■
[2015] 55 taxmann.com 484 (Hyderabad - Trib.)
IN THE ITAT HYDERABAD BENCH 'A'
Income-tax Officer (International Taxation)-I, Hyderabad
v.
Janardhan Pannir*
P.M. JAGTAP, ACCOUNTANT MEMBER
AND SMT. ASHA VIJAYARAGHAVAN, JUDICIAL MEMBER
IT APPEAL NO. 721 (HYD.) OF 2014
[ASSESSMENT YEAR 2010-11]
DECEMBER 24, 2014
Section 9 of the Income-tax Act, 1961 - Income - Deemed to accrue or arise in India (Fee for technical services) - Assessment year 2010-11 - Whether where assessee was working as consultant-cum-independent contractor in order to render services as senior drilling/operation engineer at Nigeria (outside India) to an Indian company, amount received by assessee in foreign currency for rendering said services outside India could not be brought to tax in India - Held, yes [Para 14] [In favour of assessee]
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