https://www.taxtmi.com/caselaws?id=250362 Offshore supply receipts under a distinct supply contract were held taxable in India only to the extent attributable to operations actually carried out in India; the mere fact that equipment was procured and supplied outside India did not, on these facts, make the entire receipt taxable. The earlier administrative approach based on advance ruling was treated as unsustainable in light of the later Supreme Court position. Once the revisionary order under section 263 was set aside, the consequential assessment order could not survive, and the connected appeal was restored for fresh adjudication on merits. The assessee thus obtained relief on the substantive tax issue. en-us Fri, 25 Jul 2014 00:00:00 +0530 Sun, 10 Aug 2014 07:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=250362 Offshore supply receipts under a distinct supply contract were held taxable in India only to the extent attributable to operations actually carried out in India; the mere fact that equipment was procured and supplied outside India did not, on these facts, make the entire receipt taxable. The earlier administrative approach based on advance ruling was treated as unsustainable in light of the later Supreme Court position. Once the revisionary order under section 263 was set aside, the consequential assessment order could not survive, and the connected appeal was restored for fresh adjudication on merits. The assessee thus obtained relief on the substantive tax issue. Case-Laws Income Tax Fri, 25 Jul 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=250362