https://www.taxtmi.com/caselaws?id=364580 A composite contract with severable, independently identifiable activities must be analysed stream by stream for taxability, with separate treatment for offshore supply, overseas repairs and rentals. Offshore supply completed outside India, with title passing abroad and no Indian operations, was not taxable in India as royalty or fees for technical services. Repair and related services performed entirely at overseas workstations were also not royalty or fees for technical services, and no attribution to the Indian PE arose because technical knowledge was not made available. Equipment rental for mineral oil operations fell under the presumptive regime of section 44BB, not section 44DA. en-us Fri, 13 Jul 2018 00:00:00 +0530 Wed, 29 Aug 2018 12:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=364580 A composite contract with severable, independently identifiable activities must be analysed stream by stream for taxability, with separate treatment for offshore supply, overseas repairs and rentals. Offshore supply completed outside India, with title passing abroad and no Indian operations, was not taxable in India as royalty or fees for technical services. Repair and related services performed entirely at overseas workstations were also not royalty or fees for technical services, and no attribution to the Indian PE arose because technical knowledge was not made available. Equipment rental for mineral oil operations fell under the presumptive regime of section 44BB, not section 44DA. Case-Laws Income Tax Fri, 13 Jul 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=364580