if an Indian resident open a offshore company for receiving commission income in USD from Indian company, then will the offshore company need to pay tax to Indian govt? 

provided the turnover is less than 50cr. So will POEM rules will apply or not over it? 

“Foreign Company with turnover/gross receipts of 
less than Rs. 50 Crores p.a. cannot be considered to 
be a Resident in India (Circular No. 8/2017 dated February 23, 2017)”