The assessee, a Chinese company, entered into separate offshore supply and onshore service agreements with Indian public sector undertakings for supply of optical ground wire cables and communication equipment. The Commissioner revised the assessment under section 263 by clubbing the offshore and onshore receipts and sought to tax the offshore receipts under section 44BBB. The Tribunal held that the offshore supply contract was independently executed outside India and the onshore activities were carried out through an Indian entity under a separate agreement. Following the decisions of the Supreme Court in Hyundai Heavy Industries Co. Ltd. and Ishikawajima-Harima Heavy Industries Ltd., the offshore receipts were not chargeable to tax in India. Once the receipts were not taxable under the normal provisions, section 44BBB had no application. The revision order under section 263 was therefore quashed. (AY. 2017-18).