https://www.taxtmi.com/caselaws?id=445301 ITAT Delhi held that offshore supply receipts were not taxable in India, rejecting revenue's claim of supervisory permanent establishment under India-Thailand Tax Treaty Article 5. Following coordinate bench precedent, the tribunal directed deletion of additions made by Assessing Officer for profit attribution on offshore supplies. Additionally, ITAT ruled that engineering service receipts were not royalty income, correcting departmental authorities' factual misconception regarding equipment process usage. The assessee's appeal was allowed on both issues. en-us Mon, 30 Oct 2023 00:00:00 +0530 Mon, 04 Mar 2024 16:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445301 ITAT Delhi held that offshore supply receipts were not taxable in India, rejecting revenue's claim of supervisory permanent establishment under India-Thailand Tax Treaty Article 5. Following coordinate bench precedent, the tribunal directed deletion of additions made by Assessing Officer for profit attribution on offshore supplies. Additionally, ITAT ruled that engineering service receipts were not royalty income, correcting departmental authorities' factual misconception regarding equipment process usage. The assessee's appeal was allowed on both issues. Case-Laws Income Tax Mon, 30 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445301