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    <title>2024 (3) TMI 307 - ITAT DELHI</title>
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    <description>Offshore equipment supply receipts were not taxable in India where goods were supplied on CIF terms from outside India, title passed outside India, and payment was received outside India. Separate onshore arrangements and the existence of an Indian group entity did not convert the offshore sale into a composite taxable receipt. Allocating consolidated consideration between business income and fees for technical services without a contractual basis was arbitrary and impermissible. The addition relating to offshore supply receipts was directed to be deleted.</description>
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      <description>Offshore equipment supply receipts were not taxable in India where goods were supplied on CIF terms from outside India, title passed outside India, and payment was received outside India. Separate onshore arrangements and the existence of an Indian group entity did not convert the offshore sale into a composite taxable receipt. Allocating consolidated consideration between business income and fees for technical services without a contractual basis was arbitrary and impermissible. The addition relating to offshore supply receipts was directed to be deleted.</description>
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