Applicant a Japanese company is engaged in business of steel & environmental plants and has delivered a number of Coke Dry Quenching (CDQ) units world wide. It entered in to two contracts with purchaser JSW an Indian company, for supply  of CDQ equipment for Japan portion and for China portion. It sought advance ruling. Authority held that  Amount received/receivable by applicant under equipment supply contract awarded by an Indian company for off shore supply of Coke Dry Quenching (CDQ) units would not be chargeable to tax in India as the applicant did not have any fixed place through which its business was wholly or partly carried on to be considered as PE.