Held, dismissing the appeals the Court held that no material had been placed before the court to rebut the Tribunal’s finding that work had commenced at the site only on or after January 4, 2008. The preparatory work such as travelling for obtaining tender or contract could not be deemed to be the starting point of the contract. Consequently, there was no perversity in the findings of fact rendered by the Tribunal. (1996 218 ITR (St.) 70) (AY.2008-09, 2009-10)
CIT (IT) v. Bellsea Ltd. (2023)459 ITR 375 /147 taxmann.com 488 (Delhi)(HC)
S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Threshold period of twelve months for activities in India not exceeded-Not taxable in India-DTAA-India-Cyprus.[Art. 5(2)(g), 7]