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Offshore Equipment Sale Not Taxable in India: No Permanent Establishment or Income Accrual per Transaction Rules.

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....Income accrued in India - profit on supply of equipment - offshore supply - goods were sold from outside India, thus, the risk and title were also transferred outside India and no transaction took place in India- the custom clearance, inland transportation were done by purchaser and assessee at no stage involved in the said activities - no PE involved in the sale it only done supervision after the supply of equipments - not taxable....