https://www.taxtmi.com/caselaws?id=436506 Separate contracts awarded under a bid structure, with distinct scopes of work and independent contractual parties, were treated as genuine offshore and onshore arrangements rather than an artificial split of one composite contract. On that basis, offshore supply receipts were regarded as outside Indian tax nexus in the absence of business connection, dependent agent PE, or construction PE. Receipts linked to other offshore supplies were also held outside the section 44BBB framework. For the global operation fee, treaty taxation as fees for technical services failed because the services were managerial or support-oriented and did not satisfy the make available test under the India-UK DTAA. en-us Wed, 12 Apr 2023 00:00:00 +0530 Thu, 13 Apr 2023 15:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=436506 Separate contracts awarded under a bid structure, with distinct scopes of work and independent contractual parties, were treated as genuine offshore and onshore arrangements rather than an artificial split of one composite contract. On that basis, offshore supply receipts were regarded as outside Indian tax nexus in the absence of business connection, dependent agent PE, or construction PE. Receipts linked to other offshore supplies were also held outside the section 44BBB framework. For the global operation fee, treaty taxation as fees for technical services failed because the services were managerial or support-oriented and did not satisfy the make available test under the India-UK DTAA. Case-Laws Income Tax Wed, 12 Apr 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=436506