Offshore supply receipts remain outside Indian taxation where CIF title passes abroad and contracts are genuinely separate.

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....Separate offshore-supply, domestic-supply and domestic-service contracts in a transmission project need not be treated as artificial splitting merely because project safeguards, acceptance testing and performance obligations apply. Where goods are supplied on CIF terms and title passes outside India, offshore-supply receipts are not taxable in India. An Indian associate conducting an independent business does not create a fixed-place or dependent-agent permanent establishment without legal, economic or other dependence. The presumptive computation provision for turnkey power projects does not extend to receipts from mere offshore supply under a separate contract.....