https://www.taxtmi.com/caselaws?id=763183 Offshore supply receipts under contracts for elevators and escalators were held not taxable in India where the supplier's role was confined to design, manufacture and offshore supply, and onshore work was separately assigned to the Indian consortium member. The contracts showed clear segregation of obligations, consideration and payment currency, and title in the goods passed outside India on CIF terms. The Tribunal applied the principle that only income attributable to operations carried out in India can be taxed under section 9(1)(i) and Article 7 of the India-China DTAA. As no taxable operations by the supplier in India were shown, the addition was deleted. en-us Tue, 26 Nov 2024 00:00:00 +0530 Fri, 13 Dec 2024 14:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763183 Offshore supply receipts under contracts for elevators and escalators were held not taxable in India where the supplier's role was confined to design, manufacture and offshore supply, and onshore work was separately assigned to the Indian consortium member. The contracts showed clear segregation of obligations, consideration and payment currency, and title in the goods passed outside India on CIF terms. The Tribunal applied the principle that only income attributable to operations carried out in India can be taxed under section 9(1)(i) and Article 7 of the India-China DTAA. As no taxable operations by the supplier in India were shown, the addition was deleted. Case-Laws Income Tax Tue, 26 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763183