Mitsui & Co. Ltd. v. DDIT - Taxpublishers.in

Case Laws Analysis
REFERRED CIT v. E-Funds IT Solution & Ors. 2014 TaxPub(DT) 1849 (Del-HC)
REFERRED Rolls Royce PLC v. Director of IT (International Taxation) 2012 TaxPub(DT) 0508 (Del-HC)
REFERRED Director of Income-tax (International Taxation) & Anr. v. Morgan Stanley & Co. & Anr. 2007 TaxPub(DT) 1354 (SC)
REFERRED Controller of Estate Duty v. Smt. S. Saraswathy 1999 TaxPub(DT) 0423 (Mad-HC)
REFERRED Vuppala Nagalingam & Sons v. Commissioner of Income Tax 1999 TaxPub(DT) 0423 (AP-HC)
REFERRED TVM Limited v. Commissioner of Income Tax 1999 TaxPub(DT) 0423 (AAR)
REFERRED CIT v. A. Raman & Co. 1968 TaxPub(DT) 0197 (SC)

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The Tax PublishersITA No. 4377/Del/2016 2020 TaxPub(DT) 3837 (Del-Trib) IN THE ITAT, DELHI BENCH R.K. PANDA, A.M. & SUCHITRA KAMBLE, J.M. Mitsui & Co. Ltd. v. DDIT ITA No. 4377/Del/2016 22 September, 2020 Assessee by: Ved Jain Sr. Advocate, Ashish Goel, CA Department by: Satpal Gulati, Commissioner ORDER *R.K. Panda, A.M.* This appeal filed by the assessee is directed against the Order, dated 29-5-2015 of the learned Commissioner (Appeals)-43, New Delhi relating to assessment year 2010-11 2. The facts of the case, in brief, are that the assessee is a company incorporated in Japan and is one of biggest trading houses of the world. The assessee is involved in trading from needle to airplane engines. Assessee also undertakes several projects in connection with big industrial installations power projects. 3. It filed its return of income on 15-10-2010 declaring income of Rs. 2,87,80,329. The assessing officer during the course of assessment proceedings noted that the assessee has received consideration for executing two projects, namely, Teesta & Purulia Projects. The assessee has entered into contracts with National Hydroelectric Power Corporation Ltd. (NHPC) on 6-12-2001 for carrying out Electrical and mechanical Works of Teesta H.E. Project (3 X 1 70 MW (Stage-V) Sikkim, India). These agreements are-- (a) First Contract--For CIF/CIP Supply of all offshore equipments and materials including Mandatory Spares for Lot-6 Electrical & Mechanical works of Teesta HE Project (Stage-V). SUBSCRIBE FOR FULL CONTENT

The Tax PublishersITA No. 4377/Del/2016
2020 TaxPub(DT) 3837 (Del-Trib)

IN THE ITAT, DELHI BENCH

R.K. PANDA, A.M. & SUCHITRA KAMBLE, J.M.

Mitsui & Co. Ltd. v. DDIT

ITA No. 4377/Del/2016

22 September, 2020

Assessee by: Ved Jain Sr. Advocate, Ashish Goel, CA

Department by: Satpal Gulati, Commissioner

ORDER

R.K. Panda, A.M.

This appeal filed by the assessee is directed against the Order, dated 29-5-2015 of the learned Commissioner (Appeals)-43, New Delhi relating to assessment year 2010-11

2. The facts of the case, in brief, are that the assessee is a company incorporated in Japan and is one of biggest trading houses of the world. The assessee is involved in trading from needle to airplane engines. Assessee also undertakes several projects in connection with big industrial installations power projects.

3. It filed its return of income on 15-10-2010 declaring income of Rs. 2,87,80,329. The assessing officer during the course of assessment proceedings noted that the assessee has received consideration for executing two projects, namely, Teesta & Purulia Projects. The assessee has entered into contracts with National Hydroelectric Power Corporation Ltd. (NHPC) on 6-12-2001 for carrying out Electrical and mechanical Works of Teesta H.E. Project (3 X 1 70 MW (Stage-V) Sikkim, India). These agreements are--

(a) First Contract--For CIF/CIP Supply of all offshore equipments and materials including Mandatory Spares for Lot-6 Electrical & Mechanical works of Teesta HE Project (Stage-V).