https://www.taxtmi.com/caselaws?id=784226 Where drawings and designs are contractually and commercially inseparable from offshore supply of plant and equipment, the composite receipt is treated as offshore supply completed outside India and not taxed as fees for technical services or business income in India. Supervisory receipts for erection and commissioning are taxable according to their treaty character; short-duration supervision fell within fees for technical services, while longer-duration supervision through a permanent establishment had to be assessed on a net basis under Article 7. If audited books were not validly rejected and showed a loss from that activity, no taxable income could be brought to tax on that head. en-us Wed, 24 Dec 2025 00:00:00 +0530 Mon, 05 Jan 2026 17:27:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784226 Where drawings and designs are contractually and commercially inseparable from offshore supply of plant and equipment, the composite receipt is treated as offshore supply completed outside India and not taxed as fees for technical services or business income in India. Supervisory receipts for erection and commissioning are taxable according to their treaty character; short-duration supervision fell within fees for technical services, while longer-duration supervision through a permanent establishment had to be assessed on a net basis under Article 7. If audited books were not validly rejected and showed a loss from that activity, no taxable income could be brought to tax on that head. Case-Laws Income Tax Wed, 24 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784226