https://www.taxtmi.com/caselaws?id=784658 Offshore supply of KD parts was treated as completed outside India because invoices, bills of lading, insurance material and affidavit evidence showed principal-to-principal transfer of title and risk abroad; the inspection clause did not alter that result. A supervisory permanent establishment was not established because the seconded employees were found to be working for the Indian company, and reporting, information sharing or cost-to-cost salary reimbursement did not prove operational control by the foreign enterprise. A fixed place permanent establishment was also rejected because the subsidiary's premises were not shown to be at the foreign enterprise's disposal for its own business. With no PE and no taxable offshore supply connection, the attributed income addition could not stand. en-us Wed, 07 Jan 2026 00:00:00 +0530 Mon, 12 Jan 2026 12:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784658 Offshore supply of KD parts was treated as completed outside India because invoices, bills of lading, insurance material and affidavit evidence showed principal-to-principal transfer of title and risk abroad; the inspection clause did not alter that result. A supervisory permanent establishment was not established because the seconded employees were found to be working for the Indian company, and reporting, information sharing or cost-to-cost salary reimbursement did not prove operational control by the foreign enterprise. A fixed place permanent establishment was also rejected because the subsidiary's premises were not shown to be at the foreign enterprise's disposal for its own business. With no PE and no taxable offshore supply connection, the attributed income addition could not stand. Case-Laws Income Tax Wed, 07 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784658