Taxation of non-resident turnkey contractors: FOB sales outside India not taxable; technical and construction receipts taxed by source rules. Foreign consortium members are separate taxable entities; overall coordination agreements do not create partnership. FOB sales where title passes outside India are not taxable in India. Fees for planning, design and engineering are taxable as technical services subject to domestic rates or applicable double taxation agreements. Civil construction and erection/testing work performed in India attract a deemed-profits attribution of gross receipts for taxation where conditions are met. Separately identifiable transportation charges are governed by the rules for operation of ships or aircraft. Contracts by different foreign companies must be treated distinctly; guidance applies after the effective date.