Taxation of non-resident contractor income: apportion taxable receipts with prescribed profit allocation for onshore activities. Non-resident contractors' income from turnkey oil and gas contracts must be apportioned between activities abroad and activities in India; income attributable to installation, hook-up and commissioning performed in India is taxable in India, and where sale occurs in India a portion of the profits attributable to the sale is also taxable. A prescribed method allocates a fixed proportion of gross receipts as net income and designates a smaller proportion of that income to the sale element; fees for technical services are excluded from these guidelines and taxed under treaty or statutory rules. Application requires the non-resident's agreement and is time limited.
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.
Taxation of non-resident contractor income: apportion taxable receipts with prescribed profit allocation for onshore activities.
Non-resident contractors' income from turnkey oil and gas contracts must be apportioned between activities abroad and activities in India; income attributable to installation, hook-up and commissioning performed in India is taxable in India, and where sale occurs in India a portion of the profits attributable to the sale is also taxable. A prescribed method allocates a fixed proportion of gross receipts as net income and designates a smaller proportion of that income to the sale element; fees for technical services are excluded from these guidelines and taxed under treaty or statutory rules. Application requires the non-resident's agreement and is time limited.
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