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    <title>2011 (7) TMI 98 - AUTHORITY FOR ADVANCE RULINGS</title>
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    <description>Receipts from offshore supply contracts were stated to be outside India&#039;s taxing jurisdiction where title to goods passed outside India and the supply consideration was separately identifiable. The presence of onshore obligations did not, by itself, make the offshore receipts taxable in India, and a permanent establishment for onshore activities did not alter that result when it had no role in the offshore sale portion. The analysis applied the settled principle that offshore supply income is not taxable in India when the sale is completed outside India and the consideration is independently ascertainable.</description>
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      <title>2011 (7) TMI 98 - AUTHORITY FOR ADVANCE RULINGS</title>
      <link>https://www.taxtmi.com/caselaws?id=204741</link>
      <description>Receipts from offshore supply contracts were stated to be outside India&#039;s taxing jurisdiction where title to goods passed outside India and the supply consideration was separately identifiable. The presence of onshore obligations did not, by itself, make the offshore receipts taxable in India, and a permanent establishment for onshore activities did not alter that result when it had no role in the offshore sale portion. The analysis applied the settled principle that offshore supply income is not taxable in India when the sale is completed outside India and the consideration is independently ascertainable.</description>
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