Assessee, a Ireland based company, which is  engaged in business of manufacturing highly sophisticated complex, technology advanced and expensive equipment. It had supplied equipment to Indian customers and claimed same as offshore sale of goods and claimed that since revenue had accrued outside India as per provisions of section 5, same was not taxable in India-Assessing Officer was of view that assessee was providing sophisticated equipment’s to its client which could be put to use by it only as well as rendering support services and had taxed receipt from offshore sale of goods as fees for technical services. On appeal the Tribunal held that the  assessee had submitted copy of invoices and purchase order and in invoices description of sale of equipment, number of quantity, price of item sold and details of buyer to whom shipment of goods was provided which demonstrated that assessee had received amount on sale of equipment. The  Assessing Officer had not brought on record any clinching evidence to substantiate that assessee had received impugned amount for rendering of services. Accordingly the addition is deleted. (AY. 2018-19)