https://www.taxtmi.com/caselaws?id=781447 Separate offshore and onshore project contracts, supported by distinct scopes and counterparties, were not treated as a taxable composite arrangement merely because the foreign contractor retained overall responsibility for completion. The Revenue failed to establish a business connection, dependent agent PE, or construction PE in India, so offshore supply receipts were not taxable and section 44BBB did not apply. Global operation fees were also held not taxable as fees for technical services because the services were largely managerial and coordination-based and did not make available technical knowledge, skill, or experience under the India-UK DTAA. The impugned additions were deleted, with one computational issue remanded for verification. en-us Mon, 10 Nov 2025 00:00:00 +0530 Sat, 15 Nov 2025 07:56:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781447 Separate offshore and onshore project contracts, supported by distinct scopes and counterparties, were not treated as a taxable composite arrangement merely because the foreign contractor retained overall responsibility for completion. The Revenue failed to establish a business connection, dependent agent PE, or construction PE in India, so offshore supply receipts were not taxable and section 44BBB did not apply. Global operation fees were also held not taxable as fees for technical services because the services were largely managerial and coordination-based and did not make available technical knowledge, skill, or experience under the India-UK DTAA. The impugned additions were deleted, with one computational issue remanded for verification. Case-Laws Income Tax Mon, 10 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781447