https://www.taxtmi.com/caselaws?id=33860 Separately awarded contracts, independent performance and separate consideration do not by themselves establish an Association of Persons; a common design, unity of action and shared profit-making purpose are required, so the parties were not assessable as an AOP. Offshore supply receipts were not taxable in India where title passed outside India on shipment, payment was made outside India and the sale was completed on the high seas, since protective clauses on custody, risk, insurance and testing did not create Indian-source accrual. On the available facts, supervisory activities did not clearly cross the DTAA time threshold and a Permanent Establishment in India was not shown, though any proven PE would support taxation only of profits attributable to Indian operations. en-us Wed, 17 Jun 2009 00:00:00 +0530 Mon, 17 Nov 2025 14:59:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=33860 Separately awarded contracts, independent performance and separate consideration do not by themselves establish an Association of Persons; a common design, unity of action and shared profit-making purpose are required, so the parties were not assessable as an AOP. Offshore supply receipts were not taxable in India where title passed outside India on shipment, payment was made outside India and the sale was completed on the high seas, since protective clauses on custody, risk, insurance and testing did not create Indian-source accrual. On the available facts, supervisory activities did not clearly cross the DTAA time threshold and a Permanent Establishment in India was not shown, though any proven PE would support taxation only of profits attributable to Indian operations. Case-Laws Income Tax Wed, 17 Jun 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=33860