https://www.taxtmi.com/caselaws?id=220108 Receipts from offshore supply of equipment and offshore services were treated as not taxable in India where the India-Japan DTAA excluded such income under Article 7. The retrospective Explanation inserted into section 9(1) of the Income-tax Act, 1961 did not alter that position because a domestic amendment could not fasten tax on receipts already excluded by the applicable treaty. The challenge by the Revenue therefore failed, and the non-taxability of the offshore receipts was upheld. en-us Tue, 30 Oct 2012 00:00:00 +0530 Thu, 10 Jan 2013 13:03:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=220108 Receipts from offshore supply of equipment and offshore services were treated as not taxable in India where the India-Japan DTAA excluded such income under Article 7. The retrospective Explanation inserted into section 9(1) of the Income-tax Act, 1961 did not alter that position because a domestic amendment could not fasten tax on receipts already excluded by the applicable treaty. The challenge by the Revenue therefore failed, and the non-taxability of the offshore receipts was upheld. Case-Laws Income Tax Tue, 30 Oct 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=220108