Consideration for assignment of supply agreement not taxable in the absence of Permanent Establishment in India

Facts The applicant, Laird Technologies India Pvt. Ltd. is engaged in the business of designing and manufacturing antenna and battery packs for mobile phone industry. The applicant is part of Laird PLC, UK group. Another group company viz. Laird Technologies Inc., USA (Laird-US) had negotiated a Product Purchase Agreement (PPA) with Nokia Corporation, Finland to supply the products globally including in India. The PPA was entered into between Laird-US and its affiliates (as one part) and Nokia Corporation, Finland and its affiliates (as other part). Laird-US entered into an assignment agreeme...