https://www.taxtmi.com/caselaws?id=196003 A turnkey contract that separately identifies offshore supply, onshore supply, transportation and installation, with distinct pricing and currency terms, treats offshore supplies completed outside India as lacking territorial nexus with India. On those facts, the offshore supply income is not attributable to operations in India under section 9(1)(i) and is not taxable through the permanent establishment under the treaty. The note also states that presumptive estimation under sections 44BB and 44BBB cannot be applied to the full contract value once excluded offshore receipts are removed, and that interest under section 234B is not leviable on a non-resident where tax deduction at source is the payer's 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 A turnkey contract that separately identifies offshore supply, onshore supply, transportation and installation, with distinct pricing and currency terms, treats offshore supplies completed outside India as lacking territorial nexus with India. On those facts, the offshore supply income is not attributable to operations in India under section 9(1)(i) and is not taxable through the permanent establishment under the treaty. The note also states that presumptive estimation under sections 44BB and 44BBB cannot be applied to the full contract value once excluded offshore receipts are removed, and that interest under section 234B is not leviable on a non-resident where tax deduction at source is the payer's obligation. Case-Laws Income Tax Fri, 14 Oct 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=196003