https://www.taxtmi.com/caselaws?id=238298 A composite offshore installation contract was treated as divisible, so only profits attributable to the Indian permanent establishment were taxable in India; offshore fabrication and erection receipts remained outside Indian taxation. The facts also supported a project office PE, a dependent agent PE, and an installation PE in India because the office and agent were used for project-related and pre-bid activities. Section 44BB did not apply because the assessee was not providing services or facilities for mineral oil exploration or production. Interest under sections 234B and 234C was not leviable against the non-resident, and section 234D was consequential. en-us Thu, 31 Jan 2013 00:00:00 +0530 Sun, 20 Oct 2013 10:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=238298 A composite offshore installation contract was treated as divisible, so only profits attributable to the Indian permanent establishment were taxable in India; offshore fabrication and erection receipts remained outside Indian taxation. The facts also supported a project office PE, a dependent agent PE, and an installation PE in India because the office and agent were used for project-related and pre-bid activities. Section 44BB did not apply because the assessee was not providing services or facilities for mineral oil exploration or production. Interest under sections 234B and 234C was not leviable against the non-resident, and section 234D was consequential. Case-Laws Income Tax Thu, 31 Jan 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=238298