https://www.taxtmi.com/caselaws?id=437462 Offshore supply receipts from a Singapore resident's equipment contracts were analysed under Article 7 of the India-Singapore DTAA against section 44BB of the Income-tax Act. The text states that only profits directly or indirectly attributable to the permanent establishment in India may be taxed, and that the same attribution method should ordinarily be followed year after year unless there is good and sufficient reason to depart from it. On that basis, a change in method without any material change in facts was treated as inconsistent with the treaty framework, and the settled 1% attribution approach was applied to the offshore supply receipts instead of section 44BB. en-us Wed, 15 Mar 2023 00:00:00 +0530 Wed, 31 Jan 2024 13:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=437462 Offshore supply receipts from a Singapore resident's equipment contracts were analysed under Article 7 of the India-Singapore DTAA against section 44BB of the Income-tax Act. The text states that only profits directly or indirectly attributable to the permanent establishment in India may be taxed, and that the same attribution method should ordinarily be followed year after year unless there is good and sufficient reason to depart from it. On that basis, a change in method without any material change in facts was treated as inconsistent with the treaty framework, and the settled 1% attribution approach was applied to the offshore supply receipts instead of section 44BB. Case-Laws Income Tax Wed, 15 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=437462