https://www.taxtmi.com/caselaws?id=755481 The ITAT Mumbai held that amounts received by a non-resident company under offshore supply contracts are not taxable in India under section 44BBB. The tribunal followed its consistent precedent from earlier assessment years, ruling that offshore supply contract receipts cannot form part of business income chargeable under section 44BBB. Despite the composite nature of the contract requiring post-sale functions, income from offshore equipment supply remained non-taxable in India. The revenue's alternative argument regarding service contract taxation under section 44BB was rejected as an impermissible attempt to improve the assessment officer's case. The assessee's appeal was allowed. en-us Tue, 12 Dec 2023 00:00:00 +0530 Fri, 12 Jul 2024 11:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755481 The ITAT Mumbai held that amounts received by a non-resident company under offshore supply contracts are not taxable in India under section 44BBB. The tribunal followed its consistent precedent from earlier assessment years, ruling that offshore supply contract receipts cannot form part of business income chargeable under section 44BBB. Despite the composite nature of the contract requiring post-sale functions, income from offshore equipment supply remained non-taxable in India. The revenue's alternative argument regarding service contract taxation under section 44BB was rejected as an impermissible attempt to improve the assessment officer's case. The assessee's appeal was allowed. Case-Laws Income Tax Tue, 12 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755481