https://www.taxtmi.com/caselaws?id=3467 Offshore supply of equipment and materials was treated as not taxable in India where the contract separately identified offshore and onshore components, title passed outside India, payment was made outside India, and no operations generating that income were carried out in India. Offshore services were taxed only to the extent attributable to operations in India, because fees for technical services required a sufficient territorial nexus and the services were rendered outside India without operative involvement of the permanent establishment. The principle stated is that a non-resident is taxable only on income with a real Indian nexus, and treaty attribution depends on effective connection with the permanent establishment's own involvement. en-us Thu, 04 Jan 2007 00:00:00 +0530 Mon, 16 Feb 2026 11:42:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=3467 Offshore supply of equipment and materials was treated as not taxable in India where the contract separately identified offshore and onshore components, title passed outside India, payment was made outside India, and no operations generating that income were carried out in India. Offshore services were taxed only to the extent attributable to operations in India, because fees for technical services required a sufficient territorial nexus and the services were rendered outside India without operative involvement of the permanent establishment. The principle stated is that a non-resident is taxable only on income with a real Indian nexus, and treaty attribution depends on effective connection with the permanent establishment's own involvement. Case-Laws Income Tax Thu, 04 Jan 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=3467