https://www.taxtmi.com/caselaws?id=244913 A non-resident contract with separately identifiable consideration for offshore supply, onshore supply, onshore services, and design and engineering was not treated as a single composite receipt for Indian tax purposes. Offshore supply, where title and payment passed outside India, was not taxable in India by itself; however, the embedded consideration for services rendered in India was taxable on an apportionment basis under territorial nexus and PE attribution principles. Design and engineering receipts were characterised as fees for technical services, and onshore items were taxable only to the extent of actual taxable events in the relevant year. For transfer pricing, TNMM had to be applied on a consistent total operating cost base for both the tested party and comparables, so a fractured cost base was impermissible. en-us Wed, 26 Feb 2014 00:00:00 +0530 Sat, 21 Mar 2015 15:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=244913 A non-resident contract with separately identifiable consideration for offshore supply, onshore supply, onshore services, and design and engineering was not treated as a single composite receipt for Indian tax purposes. Offshore supply, where title and payment passed outside India, was not taxable in India by itself; however, the embedded consideration for services rendered in India was taxable on an apportionment basis under territorial nexus and PE attribution principles. Design and engineering receipts were characterised as fees for technical services, and onshore items were taxable only to the extent of actual taxable events in the relevant year. For transfer pricing, TNMM had to be applied on a consistent total operating cost base for both the tested party and comparables, so a fractured cost base was impermissible. Case-Laws Income Tax Wed, 26 Feb 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=244913