W.P.(C) No. 7416/2012 Page 1 of 25

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IN THE HIGH COURT OF DELHI AT NEW DELHI

Reserved on : 13^th May 2016

Decision on : 2^nd June 2016

+

W.P (C) No. 7416/2012

TECHNIP SINGAPORE PTE LTD.

..... Petitioner

Through: Mr. Percy Pardiwala, Senior Advocate

With Mr. Sanat Kapoor and Ms. Ananya Kapoor

versus

DIRECTOR OF INCOME TAX & ANR.

..... Respondent

Through: Mr. Rahul Chaudhary, Senior Standing

Counsel with Mr. Raghvendra Singh, Junior

Standing counsel.

CORAM:

JUSTICE S.MURALIDHAR

JUSTICE VIBHU BAKHRU

J U D G M E N T

%

02.06.2016

Dr. S. Muralidhar, J.:

1. An order dated 15^th February 2012 passed by the Authority for Advance

Rulings ('AAR') (Income Tax) in AA No. 936 of 2010 has been challenged

in this writ petition filed by Technip Singapore Pte Ltd. (formerly known as

Global Industries Asia Pacific Pte. Ltd.), a company incorporated in

Singapore. The Petitioner, a resident of Singapore, is admittedly entitled to

the benefit of India-Singapore Double Tax Avoidance Agreement

(hereinafter „DTAA‟).

2016: