https://www.taxtmi.com/caselaws?id=797462 Offshore sales by a non-resident to an Indian affiliate or customers are not taxable in India where contracts are concluded and title and risk pass outside India, and no sales-related operations are undertaken in India. Under the business-connection rule, only income attributable to Indian operations may be taxed. An Indian affiliate does not create a fixed-place permanent establishment unless its premises are at the foreign enterprise's disposal, and does not create an agency permanent establishment without authority to conclude contracts, habitually secure orders, or maintain stock for delivery. In the absence of a business connection or permanent establishment, no business profits are attributable to India under the treaty. en-us Fri, 31 Jul 2026 00:00:00 +0530 Sat, 22 Aug 2026 10:33:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797462 Offshore sales by a non-resident to an Indian affiliate or customers are not taxable in India where contracts are concluded and title and risk pass outside India, and no sales-related operations are undertaken in India. Under the business-connection rule, only income attributable to Indian operations may be taxed. An Indian affiliate does not create a fixed-place permanent establishment unless its premises are at the foreign enterprise's disposal, and does not create an agency permanent establishment without authority to conclude contracts, habitually secure orders, or maintain stock for delivery. In the absence of a business connection or permanent establishment, no business profits are attributable to India under the treaty. Case-Laws Income Tax Fri, 31 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797462