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    <title>2024 (4) TMI 796 - ITAT MUMBAI</title>
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    <description>Receipts from offshore supply of escalators and elevators were held not taxable in India where the assessee&#039;s contractual role was limited to design, manufacture and offshore supply, the Indian associate handled installation and related onshore work, title passed outside India, and no operations attributable to that supply were carried out in India. The addition was deleted. The refund claim was not decided finally on merits; the Assessing Officer was directed to verify the supporting material and determine the refund in accordance with law. The dispute therefore resulted in relief on taxability, with the refund issue remitted for verification.</description>
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      <description>Receipts from offshore supply of escalators and elevators were held not taxable in India where the assessee&#039;s contractual role was limited to design, manufacture and offshore supply, the Indian associate handled installation and related onshore work, title passed outside India, and no operations attributable to that supply were carried out in India. The addition was deleted. The refund claim was not decided finally on merits; the Assessing Officer was directed to verify the supporting material and determine the refund in accordance with law. The dispute therefore resulted in relief on taxability, with the refund issue remitted for verification.</description>
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