https://www.taxtmi.com/caselaws?id=215403 A turnkey consortium that jointly bids for and performs an integrated project with common purpose and joint liability may be treated as an association of persons, even if work is internally divided and payments are separately arranged. Applying the look-at test, a composite contract for design, procurement, construction, installation and commissioning cannot be artificially split into offshore and onshore parts where the offshore elements are inextricably linked to execution of the project in India. On that basis, the contract receipts were taxable in India, and a separate permanent establishment analysis did not survive for independent consideration. en-us Tue, 20 Mar 2012 00:00:00 +0530 Sat, 04 Aug 2012 08:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=215403 A turnkey consortium that jointly bids for and performs an integrated project with common purpose and joint liability may be treated as an association of persons, even if work is internally divided and payments are separately arranged. Applying the look-at test, a composite contract for design, procurement, construction, installation and commissioning cannot be artificially split into offshore and onshore parts where the offshore elements are inextricably linked to execution of the project in India. On that basis, the contract receipts were taxable in India, and a separate permanent establishment analysis did not survive for independent consideration. Case-Laws Income Tax Tue, 20 Mar 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=215403