https://www.taxtmi.com/caselaws?id=196003 Offshore supply income under a turnkey contract is not taxable in India where the contract separately identifies offshore and onshore components, title passes and payment is received outside India, and the Indian project office has no role in the offshore transactions. Such income is not attributable to Indian operations or a permanent establishment. Receipts excluded on this basis cannot be included in a presumptive profit estimate; the presumptive provisions for specified businesses do not apply to unrelated turnkey contracts, particularly where no accounting defects are identified. Advance-tax interest is not leviable on a non-resident when tax deduction at source is the payer's primary obligation. en-us Fri, 14 Oct 2016 00:00:00 +0530 Fri, 17 Nov 2017 06:54:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=196003 Offshore supply income under a turnkey contract is not taxable in India where the contract separately identifies offshore and onshore components, title passes and payment is received outside India, and the Indian project office has no role in the offshore transactions. Such income is not attributable to Indian operations or a permanent establishment. Receipts excluded on this basis cannot be included in a presumptive profit estimate; the presumptive provisions for specified businesses do not apply to unrelated turnkey contracts, particularly where no accounting defects are identified. Advance-tax interest is not leviable on a non-resident when tax deduction at source is the payer's primary obligation. Case-Laws Income Tax Fri, 14 Oct 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=196003