https://www.taxtmi.com/caselaws?id=788130 Offshore supply receipts from equipment manufactured outside India were held not taxable in India because no material established a Permanent Establishment in India for the supply activity. The Tribunal noted that the decisive question was whether the arrangement was, in substance, a contract for equipment supply or services, and found it to be an offshore supply of equipment. Mere project duration was insufficient by itself to create a Permanent Establishment. In the absence of a Permanent Establishment, the receipts could not be attributed to India, and application of section 44BB to tax part of the offshore supply income was not sustainable. en-us Fri, 13 Mar 2026 00:00:00 +0530 Mon, 16 Mar 2026 11:34:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788130 Offshore supply receipts from equipment manufactured outside India were held not taxable in India because no material established a Permanent Establishment in India for the supply activity. The Tribunal noted that the decisive question was whether the arrangement was, in substance, a contract for equipment supply or services, and found it to be an offshore supply of equipment. Mere project duration was insufficient by itself to create a Permanent Establishment. In the absence of a Permanent Establishment, the receipts could not be attributed to India, and application of section 44BB to tax part of the offshore supply income was not sustainable. Case-Laws Income Tax Fri, 13 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788130