https://www.taxtmi.com/caselaws?id=392609 Offshore supply receipts in the Teesta and Purulia projects were held not taxable in India under section 44BBB or Article 7 of the India-Japan DTAA because the supply contracts were separate, title passed outside India, and the permanent establishment had no role in the offshore segment. The Liaison Office was not treated as a permanent establishment, and Mitsui India Private Limited was not found to be a dependent agent permanent establishment because the treaty conditions for habitual authority, stock maintenance, or order procurement were not established. Where the Indian entity had already been remunerated at arm's length for its functions, no further profit attribution to India was permissible. en-us Tue, 07 Jan 2020 00:00:00 +0530 Tue, 25 Feb 2020 05:48:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=392609 Offshore supply receipts in the Teesta and Purulia projects were held not taxable in India under section 44BBB or Article 7 of the India-Japan DTAA because the supply contracts were separate, title passed outside India, and the permanent establishment had no role in the offshore segment. The Liaison Office was not treated as a permanent establishment, and Mitsui India Private Limited was not found to be a dependent agent permanent establishment because the treaty conditions for habitual authority, stock maintenance, or order procurement were not established. Where the Indian entity had already been remunerated at arm's length for its functions, no further profit attribution to India was permissible. Case-Laws Income Tax Tue, 07 Jan 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=392609