https://www.taxtmi.com/caselaws?id=412975 No permanent establishment in India was established because the project office opened only on 01.02.2011 and, before that date, there was no branch office, sales office, factory site or other fixed place of business. Occasional visits for negotiation, signing or site inspection did not create a fixed place PE, the applicable DTAA contained no service PE clause, and the installation PE threshold was not met. As the assessee had also offered supervisory income attributable to the project office, the offshore supply of equipment and chemicals on FOB terms, with acceptance testing outside India, remained outside Indian tax net on the facts found. The Revenue's challenge failed. en-us Thu, 30 Sep 2021 00:00:00 +0530 Fri, 01 Oct 2021 08:34:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=412975 No permanent establishment in India was established because the project office opened only on 01.02.2011 and, before that date, there was no branch office, sales office, factory site or other fixed place of business. Occasional visits for negotiation, signing or site inspection did not create a fixed place PE, the applicable DTAA contained no service PE clause, and the installation PE threshold was not met. As the assessee had also offered supervisory income attributable to the project office, the offshore supply of equipment and chemicals on FOB terms, with acceptance testing outside India, remained outside Indian tax net on the facts found. The Revenue's challenge failed. Case-Laws Income Tax Thu, 30 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=412975