https://www.taxtmi.com/caselaws?id=32902 In a composite turnkey arrangement, offshore supply was held taxable in India where the contracts, correspondence, site control and operational conduct showed an integrated project with a real nexus to Indian operations and material involvement of the permanent establishment and business connection. The mere passing of title outside India was not decisive. However, the fixation of 75% of Contract I receipts as taxable lacked adequate reasoning, so the quantification of the attributable profit was set aside and remitted to the Tribunal for fresh determination on the existing material after hearing the parties. en-us Mon, 12 Jan 2009 00:00:00 +0530 Mon, 17 Nov 2025 14:17:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=32902 In a composite turnkey arrangement, offshore supply was held taxable in India where the contracts, correspondence, site control and operational conduct showed an integrated project with a real nexus to Indian operations and material involvement of the permanent establishment and business connection. The mere passing of title outside India was not decisive. However, the fixation of 75% of Contract I receipts as taxable lacked adequate reasoning, so the quantification of the attributable profit was set aside and remitted to the Tribunal for fresh determination on the existing material after hearing the parties. Case-Laws Income Tax Mon, 12 Jan 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=32902