https://www.taxtmi.com/caselaws?id=346679 For tax purposes, connected agreements are to be tested by the parties' contractual intention and actual allocation of obligations, not by the tender alone. Here, the three project agreements were treated as separate contracts rather than one composite arrangement, because each had distinct scope, timing and performance obligations. A permanent establishment in India arose only for the first contract, based on onshore site investigation and approval work, and did not extend to the offshore supply contract. Offshore supply completed entirely outside India was not taxable merely because it formed part of a larger project. en-us Fri, 28 Apr 2017 00:00:00 +0530 Mon, 21 Aug 2017 21:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=346679 For tax purposes, connected agreements are to be tested by the parties' contractual intention and actual allocation of obligations, not by the tender alone. Here, the three project agreements were treated as separate contracts rather than one composite arrangement, because each had distinct scope, timing and performance obligations. A permanent establishment in India arose only for the first contract, based on onshore site investigation and approval work, and did not extend to the offshore supply contract. Offshore supply completed entirely outside India was not taxable merely because it formed part of a larger project. Case-Laws Income Tax Fri, 28 Apr 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=346679