https://www.taxtmi.com/caselaws?id=209330 Offshore supply receipts under a composite contract were held not taxable in India where the supply agreement provided separate consideration, payment in foreign exchange, and transfer of title outside India on loading and document delivery. The onshore erection contract was separately priced and concerned services in India, so its terms could not be used to mix the offshore supply consideration with Indian operations. The existence of a project office or business connection did not by itself make the offshore receipt taxable, because only income attributable to operations carried out in India can be taxed. Applying Ishikawajma, the Court held that the offshore supply income did not accrue or arise in India and the levy on that receipt could not stand. en-us Fri, 24 Dec 2010 00:00:00 +0530 Mon, 22 Jul 2013 18:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=209330 Offshore supply receipts under a composite contract were held not taxable in India where the supply agreement provided separate consideration, payment in foreign exchange, and transfer of title outside India on loading and document delivery. The onshore erection contract was separately priced and concerned services in India, so its terms could not be used to mix the offshore supply consideration with Indian operations. The existence of a project office or business connection did not by itself make the offshore receipt taxable, because only income attributable to operations carried out in India can be taxed. Applying Ishikawajma, the Court held that the offshore supply income did not accrue or arise in India and the levy on that receipt could not stand. Case-Laws Income Tax Fri, 24 Dec 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=209330