https://www.taxtmi.com/caselaws?id=395677 Offshore supply receipts under a composite contract were treated as arising from separate, divisible activities, and because title passed outside India, no part of the supply was carried out in India, and the Indian permanent establishment had no role, the receipts were not taxable in India. Repair receipts for services performed outside India were also not taxable as fees for technical services or royalty: the work fell within the mineral oil operations exclusion, did not satisfy the make available condition for royalty under the treaty, and could not be attributed to the Indian permanent establishment or taxed under section 44DA. The Assessing Officer's additions were therefore unsustainable. en-us Wed, 27 May 2020 00:00:00 +0530 Mon, 01 Jun 2020 14:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=395677 Offshore supply receipts under a composite contract were treated as arising from separate, divisible activities, and because title passed outside India, no part of the supply was carried out in India, and the Indian permanent establishment had no role, the receipts were not taxable in India. Repair receipts for services performed outside India were also not taxable as fees for technical services or royalty: the work fell within the mineral oil operations exclusion, did not satisfy the make available condition for royalty under the treaty, and could not be attributed to the Indian permanent establishment or taxed under section 44DA. The Assessing Officer's additions were therefore unsustainable. Case-Laws Income Tax Wed, 27 May 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=395677