https://www.taxtmi.com/caselaws?id=260684 Profits from offshore supply of equipment were held not taxable in India because the contracts were performed outside India, title passed outside India, payment was received outside India, and a supervisory permanent establishment did not justify attribution of those profits. Income from supervisory services was attributed at 27.5% of gross revenue, as no reliable basis was shown to displace the earlier settlement-based method and the absence of books supported estimation. Receipts for designs and drawings were treated as business income, not royalty, because the materials were supplied as copyrighted articles for internal plant set-up without transfer of copyright or know-how rights. en-us Tue, 16 Jun 2015 00:00:00 +0530 Mon, 27 Jul 2026 16:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=260684 Profits from offshore supply of equipment were held not taxable in India because the contracts were performed outside India, title passed outside India, payment was received outside India, and a supervisory permanent establishment did not justify attribution of those profits. Income from supervisory services was attributed at 27.5% of gross revenue, as no reliable basis was shown to displace the earlier settlement-based method and the absence of books supported estimation. Receipts for designs and drawings were treated as business income, not royalty, because the materials were supplied as copyrighted articles for internal plant set-up without transfer of copyright or know-how rights. Case-Laws Income Tax Tue, 16 Jun 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=260684