https://www.taxtmi.com/caselaws?id=450526 Offshore supply of equipment was treated as outside India where the contracts provided CIF terms, title passed outside India, and payment was received outside India, so the sale was completed abroad and no Indian tax event arose merely because separate onshore activities existed. The article also notes that an earlier coordinate bench in the assessee's own case had taken the same view on offshore supply receipts. A consolidated consideration could not be split into business income and fee for technical services on a 60:40 basis without contractual support, and such bifurcation was arbitrary. The presence of an Indian group entity or separate onshore operations did not, by itself, make the offshore supply taxable in India. en-us Tue, 05 Mar 2024 00:00:00 +0530 Wed, 06 Mar 2024 14:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450526 Offshore supply of equipment was treated as outside India where the contracts provided CIF terms, title passed outside India, and payment was received outside India, so the sale was completed abroad and no Indian tax event arose merely because separate onshore activities existed. The article also notes that an earlier coordinate bench in the assessee's own case had taken the same view on offshore supply receipts. A consolidated consideration could not be split into business income and fee for technical services on a 60:40 basis without contractual support, and such bifurcation was arbitrary. The presence of an Indian group entity or separate onshore operations did not, by itself, make the offshore supply taxable in India. Case-Laws Income Tax Tue, 05 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450526