https://www.taxtmi.com/caselaws?id=359674 Offshore equipment supply income was treated as arising from offshore manufacture, offshore transfer of title, and offshore receipt of consideration, and in the absence of a taxable permanent establishment or proof that Indian entities habitually concluded contracts, no profits were attributable to India. Embedded software supplied with hardware was characterised as a copyrighted article or goods, not a transfer of copyright rights, so the receipts were not royalty. Initial training linked to operation of the equipment was ancillary to the sale and did not make available technical knowledge, so it was not fees for technical services. Proportionate research and development expenses were allowable in computing attributable income. en-us Tue, 24 Apr 2018 00:00:00 +0530 Thu, 03 May 2018 06:35:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=359674 Offshore equipment supply income was treated as arising from offshore manufacture, offshore transfer of title, and offshore receipt of consideration, and in the absence of a taxable permanent establishment or proof that Indian entities habitually concluded contracts, no profits were attributable to India. Embedded software supplied with hardware was characterised as a copyrighted article or goods, not a transfer of copyright rights, so the receipts were not royalty. Initial training linked to operation of the equipment was ancillary to the sale and did not make available technical knowledge, so it was not fees for technical services. Proportionate research and development expenses were allowable in computing attributable income. Case-Laws Income Tax Tue, 24 Apr 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=359674