https://www.taxtmi.com/caselaws?id=446412 Offshore supply of plant and equipment was not taxable in India where the contracts were separate, the supply was on FOB terms, title passed outside India, and payment was received outside India; the receipts did not accrue or arise in India and were not attributable to any permanent establishment nexus for that supply. Offshore drawings and designs were also not taxable as fees for technical services where they were executed outside India, were tailor-made for the equipment, and formed part of an integrated composite arrangement inseparable from the supply contract. The dominant character of the arrangement, rather than the separate pricing label, controlled the tax treatment. en-us Tue, 21 Nov 2023 00:00:00 +0530 Thu, 15 Jan 2026 13:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446412 Offshore supply of plant and equipment was not taxable in India where the contracts were separate, the supply was on FOB terms, title passed outside India, and payment was received outside India; the receipts did not accrue or arise in India and were not attributable to any permanent establishment nexus for that supply. Offshore drawings and designs were also not taxable as fees for technical services where they were executed outside India, were tailor-made for the equipment, and formed part of an integrated composite arrangement inseparable from the supply contract. The dominant character of the arrangement, rather than the separate pricing label, controlled the tax treatment. Case-Laws Income Tax Tue, 21 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446412