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    <title>2019 (10) TMI 121 - ITAT MUMBAI</title>
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    <description>Offshore sales completed outside India on a principal-to-principal basis, with title and delivery passing abroad, did not create a fixed place or dependent agent permanent establishment or business connection in India where the Indian group entity had no place at the non-resident&#039;s disposal and no authority to conclude contracts. The related offshore supply income was therefore not taxable in India. As the assessee was a non-resident whose income was subject to withholding tax, advance-tax liability was not attracted on the same basis, and interest under sections 234B and 234C was deleted or required to be recomputed accordingly.</description>
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      <description>Offshore sales completed outside India on a principal-to-principal basis, with title and delivery passing abroad, did not create a fixed place or dependent agent permanent establishment or business connection in India where the Indian group entity had no place at the non-resident&#039;s disposal and no authority to conclude contracts. The related offshore supply income was therefore not taxable in India. As the assessee was a non-resident whose income was subject to withholding tax, advance-tax liability was not attracted on the same basis, and interest under sections 234B and 234C was deleted or required to be recomputed accordingly.</description>
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