https://www.taxtmi.com/caselaws?id=450527 No Permanent Establishment in India was established under Article 5 of the India-UK DTAA because the assessee's role was confined to manufacture and offshore supply of Subsea Production System components, while project management, engineering, procurement, construction, fabrication, transport, testing, support and installation activities were undertaken by other consortium members. In the absence of evidence of a fixed place, installation site, project office, or installation activity in India, the Revenue could not attribute a PE to the assessee. As PE was not proved, offshore supply receipts could not be taxed on a presumptive basis under section 44BB, which was therefore held inapplicable. en-us Tue, 05 Mar 2024 00:00:00 +0530 Wed, 18 Dec 2024 14:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450527 No Permanent Establishment in India was established under Article 5 of the India-UK DTAA because the assessee's role was confined to manufacture and offshore supply of Subsea Production System components, while project management, engineering, procurement, construction, fabrication, transport, testing, support and installation activities were undertaken by other consortium members. In the absence of evidence of a fixed place, installation site, project office, or installation activity in India, the Revenue could not attribute a PE to the assessee. As PE was not proved, offshore supply receipts could not be taxed on a presumptive basis under section 44BB, which was therefore held inapplicable. Case-Laws Income Tax Tue, 05 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450527