https://www.taxtmi.com/caselaws?id=761583 Offshore supply receipts were held not taxable in India where the contracts were separate, title passed outside India on FOB terms, consideration was received outside India, and the Revenue failed to establish a business connection, fixed place PE or construction PE. On that basis, attribution of profits to India and invocation of section 44BBB were rejected, and the additions relating to THDC and GEPIL offshore supply were deleted. Interest under section 234B was consequential only and survived, if at all, merely for recomputation in accordance with law. en-us Wed, 06 Nov 2024 00:00:00 +0530 Tue, 12 Nov 2024 18:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=761583 Offshore supply receipts were held not taxable in India where the contracts were separate, title passed outside India on FOB terms, consideration was received outside India, and the Revenue failed to establish a business connection, fixed place PE or construction PE. On that basis, attribution of profits to India and invocation of section 44BBB were rejected, and the additions relating to THDC and GEPIL offshore supply were deleted. Interest under section 234B was consequential only and survived, if at all, merely for recomputation in accordance with law. Case-Laws Income Tax Wed, 06 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=761583