https://www.taxtmi.com/caselaws?id=428368 Offshore supply receipts under the DMRC contract were held not taxable in India because the assessee had no taxable permanent establishment on the facts considered. The Tribunal found no material distinction from earlier years, noted that the Revenue relied on DRP findings already reversed in the assessee's own case, and applied consistency with prior coordinate bench rulings. As no distinguishing feature was shown for the year under appeal, the attempted treatment of BTIN as a permanent establishment and the resulting attribution of profits in India could not stand. The PE finding and consequential income attribution were set aside. en-us Mon, 26 Sep 2022 00:00:00 +0530 Wed, 28 Sep 2022 11:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=428368 Offshore supply receipts under the DMRC contract were held not taxable in India because the assessee had no taxable permanent establishment on the facts considered. The Tribunal found no material distinction from earlier years, noted that the Revenue relied on DRP findings already reversed in the assessee's own case, and applied consistency with prior coordinate bench rulings. As no distinguishing feature was shown for the year under appeal, the attempted treatment of BTIN as a permanent establishment and the resulting attribution of profits in India could not stand. The PE finding and consequential income attribution were set aside. Case-Laws Income Tax Mon, 26 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=428368