https://www.taxtmi.com/caselaws?id=434933 Receipts from a non-resident's offshore supply of escalators and elevators were held not taxable in India because the assessee's role was confined to design, manufacture and CIF supply outside India, while the Indian consortium partner separately handled clearance, transport, installation, testing, commissioning and maintenance. Separate scopes of work, separate invoices and separate consideration supported the finding that title in the goods passed outside India. On the principle that only income attributable to operations carried out in India can be taxed in India, the offshore supply receipts could not be brought to tax merely because the overall project also involved onshore work by another consortium member. en-us Thu, 02 Mar 2023 00:00:00 +0530 Wed, 10 May 2023 15:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=434933 Receipts from a non-resident's offshore supply of escalators and elevators were held not taxable in India because the assessee's role was confined to design, manufacture and CIF supply outside India, while the Indian consortium partner separately handled clearance, transport, installation, testing, commissioning and maintenance. Separate scopes of work, separate invoices and separate consideration supported the finding that title in the goods passed outside India. On the principle that only income attributable to operations carried out in India can be taxed in India, the offshore supply receipts could not be brought to tax merely because the overall project also involved onshore work by another consortium member. Case-Laws Income Tax Thu, 02 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=434933