https://www.taxtmi.com/caselaws?id=389651 The AAR construed the expression "a transaction" in section 245N of the Income-tax Act to permit an advance ruling application covering more than one related transaction, while unrelated transactions may stand differently. It then held that offshore supply receipts were not taxable in India where the contracts were separate offshore supply arrangements, title and risk passed outside India on FOB terms, payment was received in foreign currency, and the supply income was not shown to be attributable to any permanent establishment or other India-based nexus. The territorial nexus principle and apportionment rules were applied to exclude Indian taxability. en-us Wed, 16 Oct 2019 00:00:00 +0530 Wed, 24 Mar 2021 18:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=389651 The AAR construed the expression "a transaction" in section 245N of the Income-tax Act to permit an advance ruling application covering more than one related transaction, while unrelated transactions may stand differently. It then held that offshore supply receipts were not taxable in India where the contracts were separate offshore supply arrangements, title and risk passed outside India on FOB terms, payment was received in foreign currency, and the supply income was not shown to be attributable to any permanent establishment or other India-based nexus. The territorial nexus principle and apportionment rules were applied to exclude Indian taxability. Case-Laws Income Tax Wed, 16 Oct 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=389651