https://www.taxtmi.com/caselaws?id=446856 The ITAT Delhi held that offshore supplies of goods and equipment by a Chinese non-resident corporate entity are not taxable in India where title transfer occurs outside India. The court rejected the AO's arbitrary 60-40 allocation between fees for technical services and goods supply, finding no contractual basis for such bifurcation. The alleged PE through ZTT India Private Limited was deemed uninvolved in the offshore supply activities. Since sale incidents and title transfers completed outside India per contract terms, the receipts cannot be taxed in India. The assessee's appeals were allowed and additions deleted. en-us Wed, 29 Nov 2023 00:00:00 +0530 Wed, 13 Dec 2023 07:54:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446856 The ITAT Delhi held that offshore supplies of goods and equipment by a Chinese non-resident corporate entity are not taxable in India where title transfer occurs outside India. The court rejected the AO's arbitrary 60-40 allocation between fees for technical services and goods supply, finding no contractual basis for such bifurcation. The alleged PE through ZTT India Private Limited was deemed uninvolved in the offshore supply activities. Since sale incidents and title transfers completed outside India per contract terms, the receipts cannot be taxed in India. The assessee's appeals were allowed and additions deleted. Case-Laws Income Tax Wed, 29 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446856