https://www.taxtmi.com/caselaws?id=293529 Offshore supply receipts under separate contract segments were prima facie not taxable in India because title passed outside India, payment was received abroad, and the supply was completed outside India without artificial contract splitting. No conclusive permanent establishment was established on the material before the AAR, though income attributable to any proved PE would be taxable only to that extent. The contract consideration also contained an embedded technical services component arising from design, drawing and engineering work, which was taxable in India under the domestic deeming rule and treaty definition, with apportionment to be made on a reasonable basis. en-us Fri, 09 Aug 2019 00:00:00 +0530 Wed, 03 Mar 2021 14:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=293529 Offshore supply receipts under separate contract segments were prima facie not taxable in India because title passed outside India, payment was received abroad, and the supply was completed outside India without artificial contract splitting. No conclusive permanent establishment was established on the material before the AAR, though income attributable to any proved PE would be taxable only to that extent. The contract consideration also contained an embedded technical services component arising from design, drawing and engineering work, which was taxable in India under the domestic deeming rule and treaty definition, with apportionment to be made on a reasonable basis. Case-Laws Income Tax Fri, 09 Aug 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=293529