https://www.taxtmi.com/caselaws?id=327392 No permanent establishment in India was found because the liaison office and Indian affiliate were not shown to be at the assessee's disposal as a fixed place of business, nor to habitually conclude contracts on its behalf. The installation and commissioning work was separately performed by the Indian company on its own account, while the equipment supply remained an offshore supply with title passing outside India. As no material showed that the supply consideration included identifiable Indian operations, only income attributable to operations carried out in India could be taxed, and no part of the offshore supply income was taxable in India. Profit attribution to a permanent establishment also did not arise. en-us Wed, 04 May 2016 00:00:00 +0530 Thu, 17 Nov 2016 12:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=327392 No permanent establishment in India was found because the liaison office and Indian affiliate were not shown to be at the assessee's disposal as a fixed place of business, nor to habitually conclude contracts on its behalf. The installation and commissioning work was separately performed by the Indian company on its own account, while the equipment supply remained an offshore supply with title passing outside India. As no material showed that the supply consideration included identifiable Indian operations, only income attributable to operations carried out in India could be taxed, and no part of the offshore supply income was taxable in India. Profit attribution to a permanent establishment also did not arise. Case-Laws Income Tax Wed, 04 May 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=327392