Payments for Offshore Supply of Equipment Not Taxable in India But Payments for Supervisory Services Are Taxable in India

This case note reviews the ruling given by the Authority for Advance Rulings to Michelin Tamil Nadu Tyres Private Ltd, which held that a payment made to a foreign company outside India for the offshore supply of machinery and equipment was not taxable in India, but payments for supervisory services performed in connection with the installation of the equipment in India by third parties were taxable in India.