https://www.taxtmi.com/caselaws?id=243085 Divisible contracts for offshore and onshore work may confine Indian taxation to income attributable to activities performed in India; the offshore designing, fabrication and supply receipts under the ONGC and GMR contracts were treated as outside Indian tax net, while the HMI project required fresh examination. For inside-India operations, profit was directed to be computed at 10% of gross revenue after allowing subcontract cost, following the assessee's earlier year method. Interest from Citi Bank, Chennai was upheld as taxable at the applicable normal rate because it was effectively connected with the permanent establishment. Interest under sections 234B and 234D was sent back for reconsideration, and challenge to initiation of penalty under section 271(1)(c) was rejected as premature. en-us Tue, 30 Jul 2013 00:00:00 +0530 Sat, 25 Jan 2014 18:18:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=243085 Divisible contracts for offshore and onshore work may confine Indian taxation to income attributable to activities performed in India; the offshore designing, fabrication and supply receipts under the ONGC and GMR contracts were treated as outside Indian tax net, while the HMI project required fresh examination. For inside-India operations, profit was directed to be computed at 10% of gross revenue after allowing subcontract cost, following the assessee's earlier year method. Interest from Citi Bank, Chennai was upheld as taxable at the applicable normal rate because it was effectively connected with the permanent establishment. Interest under sections 234B and 234D was sent back for reconsideration, and challenge to initiation of penalty under section 271(1)(c) was rejected as premature. Case-Laws Income Tax Tue, 30 Jul 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=243085