https://www.taxtmi.com/caselaws?id=32101 A composite turnkey contract may make offshore supply taxable in India where the supply is not isolated from connected Indian operations and forms part of a business connection; tax is then limited to the profit reasonably attributable to operations carried out in India. Offshore services described as managerial, technical and consultancy services are treated as fees for technical services under the Act and the India-Japan treaty, and are taxable on the gross amount without apportionment on these facts. The treaty rate cap applies, and no deduction of expenses is admissible where the statutory bar for such receipts operates. en-us Mon, 11 Oct 2004 00:00:00 +0530 Thu, 15 Jan 2009 17:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=32101 A composite turnkey contract may make offshore supply taxable in India where the supply is not isolated from connected Indian operations and forms part of a business connection; tax is then limited to the profit reasonably attributable to operations carried out in India. Offshore services described as managerial, technical and consultancy services are treated as fees for technical services under the Act and the India-Japan treaty, and are taxable on the gross amount without apportionment on these facts. The treaty rate cap applies, and no deduction of expenses is admissible where the statutory bar for such receipts operates. Case-Laws Income Tax Mon, 11 Oct 2004 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=32101