Receipts from offshore services doesn’t give rise to any income accruing or arising in India hence not taxable

DSD Noell GMBH Vs ACIT (ITAT Delhi)

ITAT Delhi held that offshore services that involve offshore supply of drawings and designs are inextricably linked with the offshore supply of Plant and equipment. Accordingly, the receipts from offshore services does not give rise to any income accruing or arising in India and therefore not taxable under the Act.

Facts-

The assessee is a company and a tax resident of Germany. The assessee is engaged

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