Without remote link between activities of other projects with PE, Force of Attraction Rule not apply

Lahmeyer International GmbH Vs DDIT (ITAT Delhi) ITAT Delhi held that the Force of Attraction Rule doesn’t apply unless there is even a remote link between the activities of other projects is established with the PE. Facts- The assessee is a non-resident corporate entity incorporated under the laws of Germany and a tax resident of Germany. In the assessment years under dispute, the assessee, as stated, had undertaken contract work with certain Government/Semi-Government projects, such as, Jammu and Kashmir State Power Development Corporation– Baglihar Project (JKSPDC-BCS), JKHCL and JVL pr...