https://www.taxtmi.com/caselaws?id=434498 In a composite contract, only income attributable to operations carried out in India is taxable in India, and offshore supply completed outside India cannot be taxed merely because the supplier has a permanent establishment in India. Applying that principle, the tribunal treated the supply and installation-related obligations as divisible and noted separate consideration for each component, so the profit attribution to offshore supply was deleted. On the fixed deposit issue, interest shown in Form 26AS and credited by the bank after tax deduction was treated as accrued income; the explanation that the deposits were misplaced was rejected, and the addition was sustained. en-us Wed, 22 Feb 2023 00:00:00 +0530 Fri, 24 Feb 2023 16:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=434498 In a composite contract, only income attributable to operations carried out in India is taxable in India, and offshore supply completed outside India cannot be taxed merely because the supplier has a permanent establishment in India. Applying that principle, the tribunal treated the supply and installation-related obligations as divisible and noted separate consideration for each component, so the profit attribution to offshore supply was deleted. On the fixed deposit issue, interest shown in Form 26AS and credited by the bank after tax deduction was treated as accrued income; the explanation that the deposits were misplaced was rejected, and the addition was sustained. Case-Laws Income Tax Wed, 22 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=434498