Court held that that the demurrage paid to the non-resident buyers of iron ore in terms of the relevant sales contract was not income that accrued or arose to the non-resident buyers in India within the meaning of section 5(2)(b) read with Explanation 1(b) to section 9(1)(i) ( AY.2008-09, 2009-10)
Sesa Goa Ltd. v JCIT (2020)423 ITR 426/ 117 taxmann.com 96/193 DTR 41/ 316 CTR 446 (Bom) (HC)
S. 9(1)(i): Income deemed to accrue or arise in India – Business connection – Non -resident – Goods for export -Amount received as demurrage charges from seller in India — Held to be not taxable [ S.5 (2)(b), 40(a)(i), 172 ]
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