Mere collaborative effort and the overall responsibility for the successful performance of the project is not sufficient to constitute an AOP - AAR

By Vijay Kumar

The Authority for Advance Ruling on Wednesday ruled that

Mere collaborative effort and the overall responsibility assumed by the applicant for the successful performance of the project is not sufficient to constitute an AOP;

the sale of equipments and materials took place outside the territories of India and the income in relation thereto cannot be said to accrue or arise in India;

activities incidental to the supply of imported goods such as transportation, storage and delivery ought not to be attributed to the PE;

We bring you this important Ruling today.

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