https://www.taxtmi.com/caselaws?id=346358 A composite cross-border contract for offshore supply of BTG equipment was treated as taxable in India to the extent the profits were attributable to Indian operations. The contracts were read as a single arrangement linking supply with supervision, testing, commissioning and takeover, so title passing outside India did not by itself exclude Indian taxability. The non-resident was found to have a business connection and a supervisory permanent establishment in India, bringing attributable profits within section 9 and Article 7 of the India-China DTAA. Interest under section 234B was not leviable on the non-resident where tax was deductible at source by the payer under section 195. en-us Fri, 14 Jul 2017 00:00:00 +0530 Wed, 09 Aug 2017 16:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=346358 A composite cross-border contract for offshore supply of BTG equipment was treated as taxable in India to the extent the profits were attributable to Indian operations. The contracts were read as a single arrangement linking supply with supervision, testing, commissioning and takeover, so title passing outside India did not by itself exclude Indian taxability. The non-resident was found to have a business connection and a supervisory permanent establishment in India, bringing attributable profits within section 9 and Article 7 of the India-China DTAA. Interest under section 234B was not leviable on the non-resident where tax was deductible at source by the payer under section 195. Case-Laws Income Tax Fri, 14 Jul 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=346358