https://www.taxtmi.com/caselaws?id=440709 Under Article 7 of the applicable DTAA, profit from offshore supplies can be taxed in India only to the extent it is attributable to an Indian permanent establishment. Where the equipment was manufactured and supplied from Japan, the Indian project office's role was limited to customs-related compliance, and no substantive involvement in the offshore transaction was identified, attribution to the PE was not justified. The Tribunal also noted that the offshore segment resulted in loss, so no attributable income could be brought to tax in India. The addition was therefore deleted. en-us Wed, 19 Jul 2023 00:00:00 +0530 Tue, 20 May 2025 12:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=440709 Under Article 7 of the applicable DTAA, profit from offshore supplies can be taxed in India only to the extent it is attributable to an Indian permanent establishment. Where the equipment was manufactured and supplied from Japan, the Indian project office's role was limited to customs-related compliance, and no substantive involvement in the offshore transaction was identified, attribution to the PE was not justified. The Tribunal also noted that the offshore segment resulted in loss, so no attributable income could be brought to tax in India. The addition was therefore deleted. Case-Laws Income Tax Wed, 19 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=440709