Held that the supply of equipments and spare parts to Indian company outside India, no portion of income from offshore supply would be taxable in India. The assessee did not undertake any activity of installation and commissioning of such equipments supplied in India. (AY. 2013-14)
Sumitomo Corporation v. DCIT(IT) (2021) 191 ITD 438 (Delhi) (Trib.)
S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Supply of equipments and spare parts to Indian company-Outside India-No portion of income from offshore supply would be taxable in India-DTAA-India-Japan. [Art. 5, 7]