Dismissing the appeals the Court held that  the contract was one for designing, manufacturing, supply, testing, commissioning of passenger rolling stock and training personnel. Dominant purpose of  contract was supply of  passenger rolling stock .Amount received under contract could not be deemed to accrue or  arise in India  Dominant purpose of  contract was supply of  passenger rolling stock. Accordingly the amount received under contract could not be deemed to accrue or  arise in India therefore the tax and interest thereon levied under section 201(1A) were not valid.( AY.2011-12)