https://www.taxtmi.com/caselaws?id=247006 A consortium of two foreign companies was held not to be an Association of Persons because the arrangement showed separate scopes of work, independent risk and cost bearing, separate invoicing, and no pooling of resources, profits or common management; mere contract coordination and joint liability to the project owner were insufficient. On offshore receipts, income from supply of equipment, materials and spares completed outside India is taxable only to the extent attributable to operations in India, and offshore design and engineering services are not automatically fees for technical services where they are integral to offshore supply. The existing record was found insufficient for final determination of the offshore income issue, and the matter was remitted for fresh consideration. en-us Wed, 23 Apr 2014 00:00:00 +0530 Mon, 27 Jul 2026 16:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=247006 A consortium of two foreign companies was held not to be an Association of Persons because the arrangement showed separate scopes of work, independent risk and cost bearing, separate invoicing, and no pooling of resources, profits or common management; mere contract coordination and joint liability to the project owner were insufficient. On offshore receipts, income from supply of equipment, materials and spares completed outside India is taxable only to the extent attributable to operations in India, and offshore design and engineering services are not automatically fees for technical services where they are integral to offshore supply. The existing record was found insufficient for final determination of the offshore income issue, and the matter was remitted for fresh consideration. Case-Laws Income Tax Wed, 23 Apr 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=247006