https://www.taxtmi.com/caselaws?id=63264 Offshore project receipts were treated as outside India's taxing scope because the work relating to designing, fabrication, transportation and related activities was carried out mainly in Korea, and the assessee had no presence at the offshore site before the structures arrived. The Revenue failed to show a fixed place of business, supervisory infrastructure or other features needed to establish a permanent establishment in India. With the prior year's findings also having attained finality and the facts for the year under appeal being materially similar, the treaty rules on business profits did not allow taxation in India of receipts not attributable to an Indian permanent establishment. en-us Wed, 03 Mar 2004 00:00:00 +0530 Thu, 14 Jun 2012 18:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=63264 Offshore project receipts were treated as outside India's taxing scope because the work relating to designing, fabrication, transportation and related activities was carried out mainly in Korea, and the assessee had no presence at the offshore site before the structures arrived. The Revenue failed to show a fixed place of business, supervisory infrastructure or other features needed to establish a permanent establishment in India. With the prior year's findings also having attained finality and the facts for the year under appeal being materially similar, the treaty rules on business profits did not allow taxation in India of receipts not attributable to an Indian permanent establishment. Case-Laws Income Tax Wed, 03 Mar 2004 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=63264