https://www.taxtmi.com/caselaws?id=208919 Income from offshore supply of equipment under composite contracts was treated as separate from onshore services, and only the income attributable to operations carried out in India was liable to tax in India under Section 9 of the Income-tax Act and Article 7 of the India-Korea treaty. Because title passed outside India and the manufacture, shipment, transfer of property, delivery of documents, and receipt of consideration for the offshore supply all occurred outside India, that component was not taxable in India. The presence of a business connection or permanent establishment did not, by itself, justify taxing the offshore supply income where the Indian agent had no role in that transaction. Onshore services remained separately taxable in India. en-us Fri, 30 Sep 2011 00:00:00 +0530 Thu, 02 Feb 2012 09:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=208919 Income from offshore supply of equipment under composite contracts was treated as separate from onshore services, and only the income attributable to operations carried out in India was liable to tax in India under Section 9 of the Income-tax Act and Article 7 of the India-Korea treaty. Because title passed outside India and the manufacture, shipment, transfer of property, delivery of documents, and receipt of consideration for the offshore supply all occurred outside India, that component was not taxable in India. The presence of a business connection or permanent establishment did not, by itself, justify taxing the offshore supply income where the Indian agent had no role in that transaction. Onshore services remained separately taxable in India. Case-Laws Income Tax Fri, 30 Sep 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=208919