No permanent establishment under DTAA if three criteria are not fulfilled

Airlines Rotables Vs. JDIT (ITAT Mumbai) The assessee, a UK company, entered into an agreement with Jet Airways under which it agreed to provide Jet Airways with two segments of services, first, to carry out repairs and overhauling of aircraft components outside India and, second, to provide spares and components in the period the components were being repaired. To ensure that the spares and replacement components were readily available, the assessee maintained a stock of the components at the operating base of the airline in India. Though the stock was under the direct control of the assessee...