https://www.taxtmi.com/caselaws?id=416772 Offshore supply receipts from the Teesta and Purulia projects were held not taxable in India under the presumptive regime or the treaty business profits article, following earlier year orders in the assessee's own case. Mitsui India Pvt. Ltd. was held not to be a dependent agency permanent establishment, so no profit was attributable to Indian operations and the alternative 20% attribution view was rejected. Project income was also to be computed on receipt basis rather than mercantile accrual for the relevant receipts. All three issues were decided in favour of the assessee and against the Revenue. en-us Tue, 04 Jan 2022 00:00:00 +0530 Thu, 03 Mar 2022 17:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=416772 Offshore supply receipts from the Teesta and Purulia projects were held not taxable in India under the presumptive regime or the treaty business profits article, following earlier year orders in the assessee's own case. Mitsui India Pvt. Ltd. was held not to be a dependent agency permanent establishment, so no profit was attributable to Indian operations and the alternative 20% attribution view was rejected. Project income was also to be computed on receipt basis rather than mercantile accrual for the relevant receipts. All three issues were decided in favour of the assessee and against the Revenue. Case-Laws Income Tax Tue, 04 Jan 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=416772