https://www.taxtmi.com/caselaws?id=204691 Offshore supply under a composite turnkey contract was treated as a separate segment for tax purposes, and the mere fact that the overall arrangement was turnkey did not make that income taxable in India. Taxability depended on whether the income accrued or arose in India or was attributable to operations in India; on the facts, the offshore supply was completed outside India, its consideration was separately determined, and the project office had no role in that segment. The territorial nexus and apportionment principles in Ishikawajima-Harima were applied, while Ansaldo Energia was found inapplicable on its facts, so the offshore supply revenue was not taxable in India. en-us Thu, 30 Sep 2010 00:00:00 +0530 Wed, 08 Jun 2016 15:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=204691 Offshore supply under a composite turnkey contract was treated as a separate segment for tax purposes, and the mere fact that the overall arrangement was turnkey did not make that income taxable in India. Taxability depended on whether the income accrued or arose in India or was attributable to operations in India; on the facts, the offshore supply was completed outside India, its consideration was separately determined, and the project office had no role in that segment. The territorial nexus and apportionment principles in Ishikawajima-Harima were applied, while Ansaldo Energia was found inapplicable on its facts, so the offshore supply revenue was not taxable in India. Case-Laws Income Tax Thu, 30 Sep 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=204691