https://www.taxtmi.com/caselaws?id=751804 Turnkey contract receipts from offshore supply were examined on the contractual terms, and the analysis indicated that a composite, integrated obligation to design, supply, erect, install, commission and complete the project could bring such receipts within the Indian tax net where the offshore supply was not a standalone transaction. The attribution of 25% of offshore supply receipts to the permanent establishment and the 5% profit estimate were rejected as ad hoc because the role of the permanent establishment, the treaty position and the protocol effect had not been properly analysed. The matter was restored for contract-wise and treaty-based reconsideration. en-us Tue, 23 Apr 2024 00:00:00 +0530 Tue, 04 Mar 2025 12:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=751804 Turnkey contract receipts from offshore supply were examined on the contractual terms, and the analysis indicated that a composite, integrated obligation to design, supply, erect, install, commission and complete the project could bring such receipts within the Indian tax net where the offshore supply was not a standalone transaction. The attribution of 25% of offshore supply receipts to the permanent establishment and the 5% profit estimate were rejected as ad hoc because the role of the permanent establishment, the treaty position and the protocol effect had not been properly analysed. The matter was restored for contract-wise and treaty-based reconsideration. Case-Laws Income Tax Tue, 23 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=751804