https://www.taxtmi.com/caselaws?id=404500 In a composite turnkey contract, offshore supply receipts were not chargeable to tax in India because the equipment supply was completed outside India, ownership passed on FOB shipment, payment was made outside India, and no material linked that segment to Indian operations of the permanent establishment. By contrast, basic engineering design services and offshore advisory services were taxable in India as business profits attributable to the permanent establishment, since they formed part of the plant-setting project, involved design review and approval for the Indian project, and were rendered through the Indian project set-up. The ruling thus granted partial relief by excluding offshore supply income while sustaining taxability of the service receipts. en-us Tue, 02 Feb 2021 00:00:00 +0530 Wed, 07 Apr 2021 14:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=404500 In a composite turnkey contract, offshore supply receipts were not chargeable to tax in India because the equipment supply was completed outside India, ownership passed on FOB shipment, payment was made outside India, and no material linked that segment to Indian operations of the permanent establishment. By contrast, basic engineering design services and offshore advisory services were taxable in India as business profits attributable to the permanent establishment, since they formed part of the plant-setting project, involved design review and approval for the Indian project, and were rendered through the Indian project set-up. The ruling thus granted partial relief by excluding offshore supply income while sustaining taxability of the service receipts. Case-Laws Income Tax Tue, 02 Feb 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=404500