https://www.taxtmi.com/highlights?id=97781 The article addresses whether offshore supply receipts give rise to a Permanent Establishment in India, holding that contract duration alone cannot establish a PE; the decisive inquiry is the contract characterisation-supply of equipment versus provision of services-and the substantive allocation of ownership, risk and duties. Applying that principle, and noting absence of AO evidence showing retention of ownership/risks or a PE presence, receipts from machinery supplied and dispatched from abroad with limited installation obligations were not attributable to a PE in India, so they are not taxable in India for the year under review. en-us Tue, 17 Mar 2026 08:23:40 +0530 Tue, 17 Mar 2026 08:23:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=97781 The article addresses whether offshore supply receipts give rise to a Permanent Establishment in India, holding that contract duration alone cannot establish a PE; the decisive inquiry is the contract characterisation-supply of equipment versus provision of services-and the substantive allocation of ownership, risk and duties. Applying that principle, and noting absence of AO evidence showing retention of ownership/risks or a PE presence, receipts from machinery supplied and dispatched from abroad with limited installation obligations were not attributable to a PE in India, so they are not taxable in India for the year under review. Highlights Income Tax Tue, 17 Mar 2026 08:23:40 +0530 https://www.taxtmi.com/highlights?id=97781