Sale of equipment to an Indian party by a foreign company cannot be construed as resulting into any business connection in India

RELEVANT PARAGRAPH 9. Now let us examine the facts of the instant case to determine if the income from sale of offshore equipment is taxable in India as per the provisions of the IT Act. The offshore supply of equipment from abroad, in common parlance, means that the supply of goods is made outside India. Ordinarily in such a case, the Indian party opens a letter of credit and nominates a bank to issue irrevocable LOC favoring the foreign party. Equipment is handed over to ship and Bill of Lading etc. are delivered to the nominated bank. With such delivery of bill of lading and other relevant ...