https://www.taxtmi.com/caselaws?id=764742 Only profits attributable to operations carried out in India can be taxed where a composite contract separates offshore supply from onshore work; on the stated facts, the offshore equipment supply was completed outside India and no sufficient nexus with the Indian presence was shown. Receipts from Glidepath were treated as subcontracted through the Indian subsidiary, which was remunerated on a cost-plus arm's length basis, so no further attribution was made. Receipts from KITCOL, TTD and CIAL required verification of invoices and year-wise taxability because the claim of prior-year offer to tax could not be decided conclusively on the existing record. en-us Fri, 10 Jan 2025 00:00:00 +0530 Thu, 16 Jan 2025 14:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764742 Only profits attributable to operations carried out in India can be taxed where a composite contract separates offshore supply from onshore work; on the stated facts, the offshore equipment supply was completed outside India and no sufficient nexus with the Indian presence was shown. Receipts from Glidepath were treated as subcontracted through the Indian subsidiary, which was remunerated on a cost-plus arm's length basis, so no further attribution was made. Receipts from KITCOL, TTD and CIAL required verification of invoices and year-wise taxability because the claim of prior-year offer to tax could not be decided conclusively on the existing record. Case-Laws Income Tax Fri, 10 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764742