https://www.taxtmi.com/caselaws?id=465723 Offshore supply receipts under separately awarded foreign and onshore contracts were treated as not taxable in India where the contracts had distinct scopes, title and payment passed outside India, and no business connection, dependent agent PE, or construction PE was established. Receipts from supplies to Indian entities also failed because the record did not show a sufficient nexus with the Indian project once PE-based taxation was absent. The global operation fee was held not taxable as fees for technical services under the DTAA because the services were mainly managerial and support-oriented and did not satisfy the make available test. en-us Mon, 17 Apr 2023 00:00:00 +0530 Tue, 27 Jan 2026 11:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465723 Offshore supply receipts under separately awarded foreign and onshore contracts were treated as not taxable in India where the contracts had distinct scopes, title and payment passed outside India, and no business connection, dependent agent PE, or construction PE was established. Receipts from supplies to Indian entities also failed because the record did not show a sufficient nexus with the Indian project once PE-based taxation was absent. The global operation fee was held not taxable as fees for technical services under the DTAA because the services were mainly managerial and support-oriented and did not satisfy the make available test. Case-Laws Income Tax Mon, 17 Apr 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465723