https://www.taxtmi.com/caselaws?id=181434 A composite turnkey arrangement with identifiable supply and erection segments did not make the supply consideration chargeable in India where title in the equipment passed outside India, no part of the goods was manufactured in India, and no income was attributable to activities in India. On that basis, the supply portion was not subject to deduction of tax at source under section 195. The alleged business connection or permanent establishment of the non-resident supplier also did not render the supply receipts taxable in India, because the facts did not satisfy the attribution requirement for business profits. The supply segment was therefore treated separately from the taxable erection and commissioning element. en-us Fri, 19 Dec 2008 00:00:00 +0530 Sat, 16 Apr 2016 17:41:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=181434 A composite turnkey arrangement with identifiable supply and erection segments did not make the supply consideration chargeable in India where title in the equipment passed outside India, no part of the goods was manufactured in India, and no income was attributable to activities in India. On that basis, the supply portion was not subject to deduction of tax at source under section 195. The alleged business connection or permanent establishment of the non-resident supplier also did not render the supply receipts taxable in India, because the facts did not satisfy the attribution requirement for business profits. The supply segment was therefore treated separately from the taxable erection and commissioning element. Case-Laws Income Tax Fri, 19 Dec 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=181434