https://www.taxtmi.com/caselaws?id=469514 Offshore supply receipts were held not sustainable for attribution to an Indian installation PE where the assessee showed FOB supply, passage of title and risk outside India, separate supply and installation orders, and receipt of consideration abroad; the Tribunal found the core facts were not properly verified and remitted the issue for fresh examination. A revised expense claim, including revised audit report and additional supervision fee expenditure, was also disallowed without adequate factual verification or consideration of the remand report, so that assessment aspect was similarly set aside for de novo consideration. Interest grounds remained consequential. en-us Fri, 07 Mar 2025 00:00:00 +0530 Fri, 19 Jun 2026 19:55:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469514 Offshore supply receipts were held not sustainable for attribution to an Indian installation PE where the assessee showed FOB supply, passage of title and risk outside India, separate supply and installation orders, and receipt of consideration abroad; the Tribunal found the core facts were not properly verified and remitted the issue for fresh examination. A revised expense claim, including revised audit report and additional supervision fee expenditure, was also disallowed without adequate factual verification or consideration of the remand report, so that assessment aspect was similarly set aside for de novo consideration. Interest grounds remained consequential. Case-Laws Income Tax Fri, 07 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469514