https://www.taxtmi.com/caselaws?id=800597 Offshore supply receipts under separately executed offshore, onshore supply and onshore service contracts remain outside Indian taxation where property and payment pass outside India and no operations generating that income occur in India. CIF terms, custody obligations, performance guarantees and acceptance testing do not, by themselves, alter that result. A fixed place permanent establishment requires a place at the foreign enterprise's disposal, while a dependent agent permanent establishment requires dependent agency and requisite authority. An Indian associate conducting substantial independent business and attending limited meetings for its own onshore scope does not establish a permanent establishment, business connection, or profit attribution. Section 44BBB does not cover standalone offshore supplies with offshore transfer of property absent taxable Indian operations. en-us Tue, 29 Sep 2026 00:00:00 +0530 Thu, 08 Oct 2026 08:45:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800597 Offshore supply receipts under separately executed offshore, onshore supply and onshore service contracts remain outside Indian taxation where property and payment pass outside India and no operations generating that income occur in India. CIF terms, custody obligations, performance guarantees and acceptance testing do not, by themselves, alter that result. A fixed place permanent establishment requires a place at the foreign enterprise's disposal, while a dependent agent permanent establishment requires dependent agency and requisite authority. An Indian associate conducting substantial independent business and attending limited meetings for its own onshore scope does not establish a permanent establishment, business connection, or profit attribution. Section 44BBB does not cover standalone offshore supplies with offshore transfer of property absent taxable Indian operations. Case-Laws Income Tax Tue, 29 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800597