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    <title>2022 (4) TMI 91 - ITAT HYDERABAD</title>
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    <description>Offshore supply receipts under separately structured project contracts were held not taxable in India where manufacture and delivery occurred outside India, title and risk passed abroad, and the Indian project office had no role in those offshore activities; only income attributable to Indian activities could be taxed. The customs duty claim was remanded because the Tribunal found possible crystallisation in the relevant years and directed factual verification. The challenge to the assessments for want of a draft assessment order failed because draft orders had been issued and the DRP procedure was followed. The brought forward loss claim was restored for fresh verification.</description>
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      <title>2022 (4) TMI 91 - ITAT HYDERABAD</title>
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      <description>Offshore supply receipts under separately structured project contracts were held not taxable in India where manufacture and delivery occurred outside India, title and risk passed abroad, and the Indian project office had no role in those offshore activities; only income attributable to Indian activities could be taxed. The customs duty claim was remanded because the Tribunal found possible crystallisation in the relevant years and directed factual verification. The challenge to the assessments for want of a draft assessment order failed because draft orders had been issued and the DRP procedure was followed. The brought forward loss claim was restored for fresh verification.</description>
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