https://www.taxtmi.com/caselaws?id=63981 FOB sales completed in France were treated as outside Indian tax attribution because title and risk passed abroad, freight and insurance were borne by the Indian buyer, and the Indian role was limited to installation supervision, so no permanent establishment or business connection was found for those supplies. The note also states that expenses incurred in India for engineers and related support services were fully deductible against technical service fees under the treaty, rather than being restricted to 50 per cent. It further explains that section 44D does not prevent set-off under section 70(1), so a loss from technical service fees may be adjusted against royalty income from another source under the same head. en-us Mon, 20 Sep 1993 00:00:00 +0530 Tue, 22 Feb 2011 13:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=63981 FOB sales completed in France were treated as outside Indian tax attribution because title and risk passed abroad, freight and insurance were borne by the Indian buyer, and the Indian role was limited to installation supervision, so no permanent establishment or business connection was found for those supplies. The note also states that expenses incurred in India for engineers and related support services were fully deductible against technical service fees under the treaty, rather than being restricted to 50 per cent. It further explains that section 44D does not prevent set-off under section 70(1), so a loss from technical service fees may be adjusted against royalty income from another source under the same head. Case-Laws Income Tax Mon, 20 Sep 1993 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=63981