SOPROPHA S A Vs. STATE

JUDGEMENT

(1.) 1. The applicant "Sopropha S. A." is a company incorporated in Switzerland and is assessed to income-tax in that country. It proposes to open a branch office in India for dealing in "green coffee".

(2.) The modus operandi of the proposed business plan relevant for the purpose of advance ruling is as follows :

(3.) BASED on the above facts, the applicant has sought rulings on the following questions :