https://www.taxtmi.com/caselaws?id=797007 Offshore supply profits from equipment, integrated designs and spares were not taxable in India where manufacture and supply operations occurred abroad, title passed on FOB shipment, consideration was received abroad, and no Indian fixed place or supervisory permanent establishment carried on those supplies. The force of attraction rule did not apply without a relevant permanent establishment. Supervisory activities exceeding the treaty threshold created a supervisory permanent establishment; receipts effectively connected with it were taxable as net business profits rather than fees for technical services, avoiding gross taxation and double taxation. Project-specific designs and drawings supplied without any right to commercially exploit intellectual property constituted sale of copyrighted products, not royalty or technical services. en-us Fri, 07 Aug 2026 00:00:00 +0530 Fri, 14 Aug 2026 07:18:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797007 Offshore supply profits from equipment, integrated designs and spares were not taxable in India where manufacture and supply operations occurred abroad, title passed on FOB shipment, consideration was received abroad, and no Indian fixed place or supervisory permanent establishment carried on those supplies. The force of attraction rule did not apply without a relevant permanent establishment. Supervisory activities exceeding the treaty threshold created a supervisory permanent establishment; receipts effectively connected with it were taxable as net business profits rather than fees for technical services, avoiding gross taxation and double taxation. Project-specific designs and drawings supplied without any right to commercially exploit intellectual property constituted sale of copyrighted products, not royalty or technical services. Case-Laws Income Tax Fri, 07 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797007