https://www.taxtmi.com/caselaws?id=218292 Receipts from offshore supply of equipment under project contracts were treated as not taxable in India because the supply was completed outside India and no operations relating to that supply were carried out in India. The Tribunal applied Explanation 1(a) to Section 9(1) of the Income-tax Act, 1961, and held that where a business is not wholly carried on in India, only income reasonably attributable to operations in India can be deemed to accrue or arise in India. As no part of the offshore supply segment was connected to Indian operations, no attribution of income to India was warranted. en-us Fri, 13 Jan 2012 00:00:00 +0530 Fri, 09 Nov 2012 21:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=218292 Receipts from offshore supply of equipment under project contracts were treated as not taxable in India because the supply was completed outside India and no operations relating to that supply were carried out in India. The Tribunal applied Explanation 1(a) to Section 9(1) of the Income-tax Act, 1961, and held that where a business is not wholly carried on in India, only income reasonably attributable to operations in India can be deemed to accrue or arise in India. As no part of the offshore supply segment was connected to Indian operations, no attribution of income to India was warranted. Case-Laws Income Tax Fri, 13 Jan 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=218292