https://www.taxtmi.com/caselaws?id=440709 The ITAT Delhi held that no profit could be attributed to the assessee's Indian PE regarding offshore equipment supply transactions. The court found that while the Indian Project Office handled customs clearance, all related activities were performed by a third party, with goods merely passing through the office for customs compliance. The customs clearance activities fell under the onshore contract portion, not offshore operations. Following the binding precedent in Nokia Solutions case, the tribunal ruled that profit cannot be attributed to a PE when the assessee incurred losses. The addition was deleted in favor of the assessee. 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 The ITAT Delhi held that no profit could be attributed to the assessee's Indian PE regarding offshore equipment supply transactions. The court found that while the Indian Project Office handled customs clearance, all related activities were performed by a third party, with goods merely passing through the office for customs compliance. The customs clearance activities fell under the onshore contract portion, not offshore operations. Following the binding precedent in Nokia Solutions case, the tribunal ruled that profit cannot be attributed to a PE when the assessee incurred losses. The addition was deleted in favor of the assessee. Case-Laws Income Tax Wed, 19 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=440709