https://www.taxtmi.com/highlights?id=81377 Offshore Supply Contracts were executed and concluded outside India, hence no income deemed to accrue or arise in India as per Section 9(1) and DTAA provisions. Receipts from such contracts do not form part of business receipts for computation u/s 44BBB. Explanation 4 cannot override limitation imposed by Explanation 1(a) to Section 9(1)(i). The Tribunal, following Supreme Court's judgment in Ishikawajima-Harima Heavy Industries Limited, held that the impugned income does not form part of business receipts for Section 44BBB computation. The assessee's appeal was allowed. en-us Mon, 16 Sep 2024 07:59:08 +0530 Mon, 16 Sep 2024 07:59:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=81377 Offshore Supply Contracts were executed and concluded outside India, hence no income deemed to accrue or arise in India as per Section 9(1) and DTAA provisions. Receipts from such contracts do not form part of business receipts for computation u/s 44BBB. Explanation 4 cannot override limitation imposed by Explanation 1(a) to Section 9(1)(i). The Tribunal, following Supreme Court's judgment in Ishikawajima-Harima Heavy Industries Limited, held that the impugned income does not form part of business receipts for Section 44BBB computation. The assessee's appeal was allowed. Highlights Income Tax Mon, 16 Sep 2024 07:59:08 +0530 https://www.taxtmi.com/highlights?id=81377