https://www.taxtmi.com/caselaws?id=458643 Offshore supply receipts under a THDC contract were held not taxable in India because the supply contract was distinct, title passed outside India on FOB terms, consideration was received outside India, and the Revenue failed to prove a fixed place or construction PE or any business connection; section 44BBB was therefore inapplicable. The write-off of a rejected duty drawback claim was allowed as a business or trading loss. Interest under sections 234B and 234C was sustained only to the extent applicable on income subject to advance tax principles and tax deduction at source, with the taxpayer not treated as in default where TDS applied. MAT credit under section 115JAA for AY 2019-20 was remitted to the AO for factual verification. en-us Wed, 13 Mar 2024 00:00:00 +0530 Mon, 11 Nov 2024 18:57:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=458643 Offshore supply receipts under a THDC contract were held not taxable in India because the supply contract was distinct, title passed outside India on FOB terms, consideration was received outside India, and the Revenue failed to prove a fixed place or construction PE or any business connection; section 44BBB was therefore inapplicable. The write-off of a rejected duty drawback claim was allowed as a business or trading loss. Interest under sections 234B and 234C was sustained only to the extent applicable on income subject to advance tax principles and tax deduction at source, with the taxpayer not treated as in default where TDS applied. MAT credit under section 115JAA for AY 2019-20 was remitted to the AO for factual verification. Case-Laws Income Tax Wed, 13 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=458643