India to Tax Offshore Equipment Supply Income Under India-Austria DTAA; Profits Linked to Local Establishment Taxable.

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....Income accrued in India - income in respect of “off-shore supply” of equipment - DTAA between India and Austria - The part of the operations of supply agreement have definitely been carried out in India by the permanent establishment of the assessee and for which part of the profit from the supply agreement also need to be taxed in India in terms of the treaty between India and the Austria as the assessee relied on the treaty provisions for considering taxation of the supply agreement. - AT....