https://www.taxtmi.com/caselaws?id=784705 The revenue must establish a permanent establishment in India through treaty-based analysis and reasoned findings; a bald assumption under Article 5 is insufficient, so the PE finding could not stand. Offshore supply of goods and standard software completed outside India, with consideration also received outside India, is not taxable in India merely because the purchaser is an Indian entity; the receipts were therefore outside Indian tax charge. The additions based on assumed PE existence and attribution of profits to India were set aside, granting relief on the substantive tax issues. en-us Wed, 03 Dec 2025 00:00:00 +0530 Sat, 10 Jan 2026 08:25:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784705 The revenue must establish a permanent establishment in India through treaty-based analysis and reasoned findings; a bald assumption under Article 5 is insufficient, so the PE finding could not stand. Offshore supply of goods and standard software completed outside India, with consideration also received outside India, is not taxable in India merely because the purchaser is an Indian entity; the receipts were therefore outside Indian tax charge. The additions based on assumed PE existence and attribution of profits to India were set aside, granting relief on the substantive tax issues. Case-Laws Income Tax Wed, 03 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784705