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     (i)      Technip India Ltd.       Rs.9,16,27,713/-

     (ii)     BNP Paribas              Rs.2,06,69,284/-

     (iii)    HPCL                     Rs.258,89,82,048/-

6. For the assessment year under dispute, the assessee filed its return of income on 26.11.2019 declaring income of Rs.12,86,92,790/-. The receipts from Technip India Ltd. was offered to tax as Fee for Technical Services (FTS) on gross basis. The receipt from BNP Paribas was also offered as income. The dispute was only with regard to receipts from HPCL. After