https://www.taxtmi.com/caselaws?id=755793 Offshore design and engineering receipts under a composite contract were treated as part of the non-taxable offshore supply, because the services were inseparably linked to the plant and equipment supply and could not be isolated as independent technical fees. Onshore supervisory and commissioning receipts connected with the Indian permanent establishment were taxed under the business profits article on a net basis, while similar services to other entities were characterised as fees for technical services. Reimbursements of shared costs without any markup or profit element were not treated as technical fees, as they were only pass-through business expenditure. en-us Thu, 27 Jun 2024 00:00:00 +0530 Thu, 18 Jul 2024 12:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755793 Offshore design and engineering receipts under a composite contract were treated as part of the non-taxable offshore supply, because the services were inseparably linked to the plant and equipment supply and could not be isolated as independent technical fees. Onshore supervisory and commissioning receipts connected with the Indian permanent establishment were taxed under the business profits article on a net basis, while similar services to other entities were characterised as fees for technical services. Reimbursements of shared costs without any markup or profit element were not treated as technical fees, as they were only pass-through business expenditure. Case-Laws Income Tax Thu, 27 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755793