https://www.taxtmi.com/caselaws?id=469885 Offshore supply income of a non-resident was not taxable in India where the Indian distributor acted on a principal-to-principal basis, had no premises at the assessee's disposal, and lacked authority to conclude contracts; no fixed place PE, agency PE, or business connection was established, so profits were not attributable to India. Interest under sections 234B and 234C was also to be recomputed for a foreign company whose income was subject to deduction at source, and it did not survive as an independent adverse levy on the facts. en-us Mon, 16 Dec 2019 00:00:00 +0530 Wed, 08 Jul 2026 13:00:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469885 Offshore supply income of a non-resident was not taxable in India where the Indian distributor acted on a principal-to-principal basis, had no premises at the assessee's disposal, and lacked authority to conclude contracts; no fixed place PE, agency PE, or business connection was established, so profits were not attributable to India. Interest under sections 234B and 234C was also to be recomputed for a foreign company whose income was subject to deduction at source, and it did not survive as an independent adverse levy on the facts. Case-Laws Income Tax Mon, 16 Dec 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469885