Taxability of profits from purchase-for-export: identifiable processing before export makes purchase profits taxable under domestic law. Where a non-resident's activities are not confined to purchase of goods for export and the goods undergo any separately identifiable process by or on behalf of the non-resident before export, clause (b) of the Explanation will not apply; taxability must be determined under section 9(1)(i) read with clause (a), so profits attributable to the purchase operations and to the subsequent identifiable processes may be taxable in India.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Taxability of profits from purchase-for-export: identifiable processing before export makes purchase profits taxable under domestic law.
Where a non-resident's activities are not confined to purchase of goods for export and the goods undergo any separately identifiable process by or on behalf of the non-resident before export, clause (b) of the Explanation will not apply; taxability must be determined under section 9(1)(i) read with clause (a), so profits attributable to the purchase operations and to the subsequent identifiable processes may be taxable in India.
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