Applicant filed an application for advance ruling on whether amount received/receivable by applicant from Delhi Metro Rail Corporation Ltd. (DMRC) under purchase order in relation to offshore supplies of High Efficiency Traction Motors for RS-1 from a port in Japan to DMRC in India, is liable to tax in India under provisions of Act and/or agreement for Avoidance of Double Taxation between India and Japan (Treaty).Revenue submitted that transaction was designed prima facie for avoidance of tax, however had not brought about any material to establish same. AAR held that merely because applicant had taken over responsibility of risk of loss or damage till equipments were delivered and also that of insurance etc; it did not establish that transaction was designed prima facie for avoidance of tax.  Application was admitted.