https://www.taxtmi.com/caselaws?id=393489 Offshore sale of vehicles completed on a principal-to-principal basis, with title and delivery passing outside India, does not by itself create a permanent establishment or business connection in India where the Indian distributor is an independent entity and has no authority to conclude contracts or act as a dependent agent. On that footing, income from the sales and related receipts is not taxable in India. Once PE is negatived, attribution of profits and disallowance of warranty, marketing and promotional expenditure lose independent significance and become academic. For a non-resident, the section 234B interest issue must also be tested consistently with the underlying taxability finding and recomputed in accordance with law. en-us Wed, 04 Mar 2020 00:00:00 +0530 Wed, 08 Jul 2026 11:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=393489 Offshore sale of vehicles completed on a principal-to-principal basis, with title and delivery passing outside India, does not by itself create a permanent establishment or business connection in India where the Indian distributor is an independent entity and has no authority to conclude contracts or act as a dependent agent. On that footing, income from the sales and related receipts is not taxable in India. Once PE is negatived, attribution of profits and disallowance of warranty, marketing and promotional expenditure lose independent significance and become academic. For a non-resident, the section 234B interest issue must also be tested consistently with the underlying taxability finding and recomputed in accordance with law. Case-Laws Income Tax Wed, 04 Mar 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=393489