material was imported in India. The installation PE
was having limited task of installation and commissioning of the
project and the title to the material ... projects with ONGC on
turnkey basis. The scope of the project included works relating to pre-
engineering surveys, designing, fabrication, procurement, installation
and commissioning
hereinafter referred to as 'PE') in India as installation project did not exceed six months. It was also submitted that unless the French ... unless the Decoufle has a PE in India or unless the installation project takes more than six months time, income embedded in such payments
learned CIT-A has erred in observing as follows:
• Installation project or supervisory activities of the
appellant continued in India for more than six months ... appellant has assigned the installation project to
the Indian subsidiary, but the main responsibility for
the project continues to be of the appellant.
• Nokia India
hereinafter referred to as 'PE') in India as installation project did not exceed six months. It was also submitted that unless the French ... unless the Decoufle has a PE in India or unless the installation project takes more than six months time, income embedded in such payments
projects, which has been involved in the execution of the
project in India
• Further, the learned AO has alleged that Assessee has an 'Installation ... supply of equipments to ATC
System Project, AAI New Delhi Airport Project, provided project management services,
installation, testing and commissioning services etc. to AAI. This
beyond September 2008. That is, the assessee was involved in
the installation project much before the effective date of contract ... reads as under:-
"A building site, construction, assembly or installation
project or supervisory activities in connection therewith,
but only where such site, project
Project (WTGs) of which electrical installation is a part. It is needles to say that without electrical installation, Winfdarm Project will remain incomplete. We therefore ... which electrical installation is a part. Consequently, we hold that electrical installation is not a separate activity distinct from Windfarm Project.
11. Issue
Indian customer,
the technical support is in respect of the projects installed and has
nothing to do with the supply contract. The consideration accruing ... months ; construction, installation or
(b) a building site, a assembly projector supervisory
construction, assembly or activities in connection
installation project or therewith only if such
Indian customer,
the technical support is in respect of the projects installed and has
nothing to do with the supply contract. The consideration accruing ... months ; construction, installation or
(b) a building site, a assembly projector supervisory
construction, assembly or activities in connection
installation project or therewith only if such
Indian customer,
the technical support is in respect of the projects installed and has
nothing to do with the supply contract. The consideration accruing ... months ; construction, installation or
(b) a building site, a assembly projector supervisory
construction, assembly or activities in connection
installation project or therewith only if such
