Transition support services from corporate spinoff for India business segment - TP adjustment deleted; comparables reassessed; goodwill depreciation, ...
Qualification of fire extinguishers as aircraft parts - original duty finding under Notification No.50/2017-Sr.545 vacated; remanded for fresh adjudic...
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The article addresses whether offshore supply receipts give rise to a Permanent Establishment in India, holding that contract duration alone cannot establish a PE; the decisive inquiry is the contract characterisation-supply of equipment versus provision of services-and the substantive allocation of ownership, risk and duties. Applying that principle, and noting absence of AO evidence showing retention of ownership/risks or a PE presence, receipts from machinery supplied and dispatched from abroad with limited installation obligations were not attributable to a PE in India, so they are not taxable in India for the year under review.
The article addresses whether offshore supply receipts give rise to a Permanent Establishment in India, holding that contract duration alone cannot establish a PE; the decisive inquiry is the contract characterisation-supply of equipment versus provision of services-and the substantive allocation of ownership, risk and duties. Applying that principle, and noting absence of AO evidence showing retention of ownership/risks or a PE presence, receipts from machinery supplied and dispatched from abroad with limited installation obligations were not attributable to a PE in India, so they are not taxable in India for the year under review.
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