https://www.taxtmi.com/caselaws?id=331903 A subcontract for facade work was treated as a composite arrangement because design, engineering, supply, fabrication, erection, installation, testing and commissioning were interlinked and did not create a real bifurcation between offshore supply and onshore services. Applying Section 19 of the Sale of Goods Act, the sale was not regarded as completed outside India since intention, conduct, insurance, customs clearance, delivery obligations and continuing risk indicated that property and risk did not pass on shipment. The contract also lacked a separate offshore supply price, and the project office performed procurement and supply-related functions. Earlier offshore supply rulings were distinguished on these facts, and the entire subcontract consideration was brought to tax in India. en-us Wed, 17 Aug 2016 00:00:00 +0530 Thu, 17 Nov 2016 18:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=331903 A subcontract for facade work was treated as a composite arrangement because design, engineering, supply, fabrication, erection, installation, testing and commissioning were interlinked and did not create a real bifurcation between offshore supply and onshore services. Applying Section 19 of the Sale of Goods Act, the sale was not regarded as completed outside India since intention, conduct, insurance, customs clearance, delivery obligations and continuing risk indicated that property and risk did not pass on shipment. The contract also lacked a separate offshore supply price, and the project office performed procurement and supply-related functions. Earlier offshore supply rulings were distinguished on these facts, and the entire subcontract consideration was brought to tax in India. Case-Laws Income Tax Wed, 17 Aug 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=331903