AAR held that , title in equipment imported transferred outside India delivery of equipment outside India and consideration for supply of plant and equipment paid in Euros to Bank outside India therefore the applicant is not liable to deduct tax at source .
Michelin Tamil Nadu Tyres P. Ltd., In Re. (2018) 401 ITR 164/301 CTR 397/ 163 DTR 385 (AAR)
S. 9(1)(i):Income deemed to accrue or arise in India – Business connection – Title in equipment imported transferred outside India — Delivery of equipment outside India and consideration for supply of plant and equipment paid in Euros to Bank outside India – Not liable to deduct tax at source .[S.195 ]