https://www.taxtmi.com/caselaws?id=281419 Offshore supply profits were held not taxable in India where the contracts were concluded and performed substantially outside India, with manufacture, delivery, payment, and inspection all occurring offshore. Receipts from designs and drawings were characterised as business income from sale of a copyrighted article, not royalty or fees for technical services, because the materials were basic engineering packages supplied outside India. Supervisory services rendered through an admitted Indian permanent establishment remained attributable to India, and the 27.5% net profit rate applied to that activity was sustained on the basis of earlier identical years. en-us Fri, 08 Sep 2017 00:00:00 +0530 Tue, 18 Jun 2019 21:30:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=281419 Offshore supply profits were held not taxable in India where the contracts were concluded and performed substantially outside India, with manufacture, delivery, payment, and inspection all occurring offshore. Receipts from designs and drawings were characterised as business income from sale of a copyrighted article, not royalty or fees for technical services, because the materials were basic engineering packages supplied outside India. Supervisory services rendered through an admitted Indian permanent establishment remained attributable to India, and the 27.5% net profit rate applied to that activity was sustained on the basis of earlier identical years. Case-Laws Income Tax Fri, 08 Sep 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=281419