The Indian Income Tax Appellate Tribunal (ITAT) delivered a ruling dated 18 August 2006 in the case of Deputy Commissioner of Income Tax v. Roxon OY (103 TTJ 891) on whether profits from the supply of equipments under a turnkey project executed in India were taxable in India under the India-Finland tax treaty (the tax treaty).
(a) Facts. The taxpayer (i.e. Roxon OY) was a non-resident company incorporated in Finland. It was part of a consortium of companies, wh…