Offshore supply income under composite contracts isn't taxable in India per Section 44BBB and Article 7(6) of the India-Japan DTAA.

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....Income from offshore supplies - Income attribution - composite contracts - the income from offshore supplies is not liable to tax in India both u/s 44BBB as well as under the provisions of Article 7 r.w. para 6 of DTAA between India and Japan - AT....