Profits from off-shore supply of equipment would not be taxable if transfer of title to purchaser takes place abroad- De

Facts •           L G Cable Ltd (“LGCL”), a Korean company, was awarded two contracts by Power Grid Corporation of India Limited (“PGCIL”). •           One contract was for “onshore” execution of the Fibre Optic Cabling System Package Project involving onshore services including erection / installation, testing and communication etc of the fibre of the cabling system. The other was for “offshore” supply of equipment. •           LGCL offered to tax in India the income attributable to activities carried out in India in connection to onshore c...