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of Taxability of receipts from offshore supply of equipments - offshore supply made to Indian PSU’s which the assessee had claimed to be not chargeable to tax under Indian Taxation - Assessee company is tax resident of China - The Tribunal analyzed the terms of the contracts and previous tribunal decisions, which indicated that the transfer of title over the goods occurred outside India, making the receipts non-taxable in India. The court emphasized that the Assessing Officer's bifurcation lacked a rational basis and evidence, rendering it impermissible.
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