OrbitaxTreaty between India and Russia – Indian decision on whether purchase of test aircraft engines is contract for sale or technical services
|Treaty Development|India-Russia
The Indian Income Tax Appellate Tribunal (ITAT) delivered a ruling dated 31 March 2008 in the case of Hindustan Aeronautics Ltd. v. Income Tax Officer (2008-TIOL-390-ITAT-BANG) on whether a payment to a foreign company for procurement of aircraft engines is a contract of sale or fee for technical services (FTS).
(a) Facts. The Taxpayer (i.e. Hindustan Aeronautics Lt…
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