https://www.taxtmi.com/caselaws?id=268382 Offshore services rendered entirely outside India under a composite contract were treated as not taxable in India because they had no nexus with the permanent establishment in India. Article 7 of the India-Japan DTAA, read with section 90(2), prevailed as the more beneficial provision and limited taxation to profits attributable to operations carried out through the permanent establishment. The income from such offshore services could not be brought to tax under section 9(1)(vii) merely because the contract was composite or because the services related to offshore supply. en-us Fri, 17 Apr 2015 00:00:00 +0530 Wed, 25 Nov 2015 10:53:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=268382 Offshore services rendered entirely outside India under a composite contract were treated as not taxable in India because they had no nexus with the permanent establishment in India. Article 7 of the India-Japan DTAA, read with section 90(2), prevailed as the more beneficial provision and limited taxation to profits attributable to operations carried out through the permanent establishment. The income from such offshore services could not be brought to tax under section 9(1)(vii) merely because the contract was composite or because the services related to offshore supply. Case-Laws Income Tax Fri, 17 Apr 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=268382