https://www.taxtmi.com/caselaws?id=392899 In a customised turnkey arrangement, supply and supervision clauses were treated as inseparable because the plant was intended for installation, commissioning, testing and acceptance in India, so the offshore supply was not an independent sale concluded outside India and the related income was held to accrue or arise in India under section 9(1)(i). The Tribunal further held that the Indian supervisory presence and connected activities warranted attribution of profits to the Indian establishment, and sustained the Assessing Officer's attribution of 35% of offshore supply profit on the facts. It also upheld levy of interest under section 234B, holding that advance-tax consequences could not be avoided merely because taxability had been disputed earlier. en-us Fri, 21 Feb 2020 00:00:00 +0530 Fri, 21 Aug 2020 15:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=392899 In a customised turnkey arrangement, supply and supervision clauses were treated as inseparable because the plant was intended for installation, commissioning, testing and acceptance in India, so the offshore supply was not an independent sale concluded outside India and the related income was held to accrue or arise in India under section 9(1)(i). The Tribunal further held that the Indian supervisory presence and connected activities warranted attribution of profits to the Indian establishment, and sustained the Assessing Officer's attribution of 35% of offshore supply profit on the facts. It also upheld levy of interest under section 234B, holding that advance-tax consequences could not be avoided merely because taxability had been disputed earlier. Case-Laws Income Tax Fri, 21 Feb 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=392899