Assessee, a Russian Federation company, which is engaged in business of setting up power projects which included construction, erection of plant and machinery and testing and commissioning of power projects.  Assessee received income from offshore supply contracts and contended that since offshore supply contracts were carried out and concluded outside India, no income would be deemed to accrue or arise in India and, thus, same would not be taxable in India. Assessing Officer held that receipts from offshore supply would be part of income offered to tax under section 44BBB. The DRP affirmed the order of the AO. On appeal the Tribunal following the earlier order of the Tribunal held that  since there had been no change neither in terms of agreements nor in nature of work carried out as per said contract, finding in earlier years would hold good for impugned year and, thus, income received by assessee from offshore supply contracts would not be taxable in India. (AY. 2021-22)