https://www.taxtmi.com/caselaws?id=217308 A composite cross-border contract may be apportioned where offshore fabrication, procurement and supply are performed outside India while installation and commissioning occur in India. On the stated facts, the Indian project office and related business functions supported the existence of a fixed place, installation and dependent agent PE, but taxation is confined to profits attributable to the Indian PE. Section 44BB does not apply to construction and installation of an offshore platform outside the mineral oil prospecting or extraction context. For a non-resident subject to withholding tax, interest under sections 234B and 234C is not leviable on the basis described, and section 234D follows consequentially. en-us Fri, 05 Oct 2012 00:00:00 +0530 Fri, 08 Apr 2016 10:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=217308 A composite cross-border contract may be apportioned where offshore fabrication, procurement and supply are performed outside India while installation and commissioning occur in India. On the stated facts, the Indian project office and related business functions supported the existence of a fixed place, installation and dependent agent PE, but taxation is confined to profits attributable to the Indian PE. Section 44BB does not apply to construction and installation of an offshore platform outside the mineral oil prospecting or extraction context. For a non-resident subject to withholding tax, interest under sections 234B and 234C is not leviable on the basis described, and section 234D follows consequentially. Case-Laws Income Tax Fri, 05 Oct 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=217308