https://www.taxtmi.com/caselaws?id=758544 ITAT Mumbai held that offshore supply contracts executed and concluded outside India do not generate income deemed to accrue or arise in India under section 9(1) and DTAA provisions, making such income non-taxable. The tribunal ruled that receipts from offshore supply contracts cannot be included in business receipts for computing income under section 44BBB, as Explanation-4 cannot override the limitation imposed by Explanation-1(a) to section 9(1)(i). Following the SC precedent in Ishikawajima-Harima Heavy Industries Limited, the assessee's appeal was allowed, consistent with previous years' decisions. en-us Fri, 06 Sep 2024 00:00:00 +0530 Sat, 14 Sep 2024 10:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=758544 ITAT Mumbai held that offshore supply contracts executed and concluded outside India do not generate income deemed to accrue or arise in India under section 9(1) and DTAA provisions, making such income non-taxable. The tribunal ruled that receipts from offshore supply contracts cannot be included in business receipts for computing income under section 44BBB, as Explanation-4 cannot override the limitation imposed by Explanation-1(a) to section 9(1)(i). Following the SC precedent in Ishikawajima-Harima Heavy Industries Limited, the assessee's appeal was allowed, consistent with previous years' decisions. Case-Laws Income Tax Fri, 06 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=758544