https://www.taxtmi.com/caselaws?id=331755 Reassessment was not invalid on a change-of-opinion theory because an order under section 195(2) is only a prima facie TDS determination and not a regular assessment under section 143(3). The contract was treated as divisible, since consideration was separately allocated for supply, installation, commissioning, inspection and training; offshore supplies completed on FOB/FCA terms outside India were not taxable in India in the absence of offshore operations or a treaty PE nexus. Onshore supplies, installation and inspection receipts, and the service tax component required fresh factual examination. Attribution of 15% of gross receipts from India-linked activities was upheld, and the Revenue's higher attribution claim failed. en-us Fri, 19 Aug 2016 00:00:00 +0530 Thu, 01 Sep 2016 14:06:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=331755 Reassessment was not invalid on a change-of-opinion theory because an order under section 195(2) is only a prima facie TDS determination and not a regular assessment under section 143(3). The contract was treated as divisible, since consideration was separately allocated for supply, installation, commissioning, inspection and training; offshore supplies completed on FOB/FCA terms outside India were not taxable in India in the absence of offshore operations or a treaty PE nexus. Onshore supplies, installation and inspection receipts, and the service tax component required fresh factual examination. Attribution of 15% of gross receipts from India-linked activities was upheld, and the Revenue's higher attribution claim failed. Case-Laws Income Tax Fri, 19 Aug 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=331755