https://www.taxtmi.com/caselaws?id=793593 Offshore supply receipts were held not taxable on a presumptive basis under section 44BB because the Revenue failed to prove a fixed place or deemed permanent establishment in India. The Tribunal noted that the facts for the year were materially identical to the earlier year decided in the assessee's favour, and no fresh material had been brought to establish a permanent establishment. Applying the coordinate bench decision in the assessee's own case, it held that in the absence of a permanent establishment in India, section 44BB could not be used to bring the offshore supply receipts to tax, and the addition was deleted. en-us Wed, 27 May 2026 00:00:00 +0530 Fri, 19 Jun 2026 08:24:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793593 Offshore supply receipts were held not taxable on a presumptive basis under section 44BB because the Revenue failed to prove a fixed place or deemed permanent establishment in India. The Tribunal noted that the facts for the year were materially identical to the earlier year decided in the assessee's favour, and no fresh material had been brought to establish a permanent establishment. Applying the coordinate bench decision in the assessee's own case, it held that in the absence of a permanent establishment in India, section 44BB could not be used to bring the offshore supply receipts to tax, and the addition was deleted. Case-Laws Income Tax Wed, 27 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793593