https://www.taxtmi.com/caselaws?id=408435 Offshore supply profits were treated as non-taxable in India where the supplies were concluded outside India, title and risk passed abroad, and no taxable nexus through a permanent establishment was shown; the related denial of business loss set-off therefore could not stand. Share-transfer capital gains had to be recomputed on the basis of the agreed consideration under the non-resident share purchase agreement, subject to verification of the correct foreign exchange conversion rate and linked brought forward capital loss relief. Full TDS credit required verification against Form 26AS. Interest under section 234B was remanded for recomputation, while interest under section 234C was deleted. en-us Wed, 09 Jun 2021 00:00:00 +0530 Wed, 09 Jun 2021 14:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=408435 Offshore supply profits were treated as non-taxable in India where the supplies were concluded outside India, title and risk passed abroad, and no taxable nexus through a permanent establishment was shown; the related denial of business loss set-off therefore could not stand. Share-transfer capital gains had to be recomputed on the basis of the agreed consideration under the non-resident share purchase agreement, subject to verification of the correct foreign exchange conversion rate and linked brought forward capital loss relief. Full TDS credit required verification against Form 26AS. Interest under section 234B was remanded for recomputation, while interest under section 234C was deleted. Case-Laws Income Tax Wed, 09 Jun 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=408435