No attribution of profit in absence of permanent establishment

ESPN Star Sports Mauritius Vs DCIT (ITAT Delhi) Facts- The appellant is a partnership firm established under Mauritius Law. It is engaged in the business of selling advertisement time and programme sponsorship from Mauritius in connection with the programming via non-standard television on ESPN, Star Sports and Star Cricket programming services. During the year under consideration, the appellant also entered into such services with respect to ESPN HD channel. AO proceeded by attribution of profit to PE and attributed 30% of the gross advertising revenue and made attribution of INR 103,32,02,03...