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    <title>2008 (8) TMI 406 - ITAT DELHI-I</title>
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    <description>Offshore supply of equipment completed outside India, with title passing on shipment and payment received abroad, was held not taxable in India because the offshore sale was a separate commercial transaction and no part of that profit was attributable to Indian operations. The related onshore erection, testing and commissioning obligations were treated as separate consideration and trade warranties, not as conditions delaying transfer of title. For a non-resident whose receipts were subject to tax deduction at source, no advance tax liability arose and interest for default in advance tax was not leviable. The offshore supply addition and consequential interest levy were deleted.</description>
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    <pubDate>Fri, 08 Aug 2008 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=65558</link>
      <description>Offshore supply of equipment completed outside India, with title passing on shipment and payment received abroad, was held not taxable in India because the offshore sale was a separate commercial transaction and no part of that profit was attributable to Indian operations. The related onshore erection, testing and commissioning obligations were treated as separate consideration and trade warranties, not as conditions delaying transfer of title. For a non-resident whose receipts were subject to tax deduction at source, no advance tax liability arose and interest for default in advance tax was not leviable. The offshore supply addition and consequential interest levy were deleted.</description>
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