OrbitaxTreaty between India and United Arab Emirates – Indian decision on taxability of income for work performed both offshore and onshore
|Treaty Development|India; United Arab Emirates
The Income Tax Appellate Tribunal (ITAT) delivered a decision on 12 October 2012 in the case of National Petroleum Construction Company v. ADIT (ITA No. 5168/Del/2010) where it held that a contract could be divided into offshore and onshore components, and that the offshore components were not taxable in India.
(a) Facts. The Taxpayer (i.e. National Petroleum Construction Company)…
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