Indian subsidiary does not constitutes a PE in India: ITAT Delhi

M/s. Nokia Networks OY vs JCIT (ITAT Delhi) Delhi ITAT (Special Bench) Ruling – Whether the Indian subsidiary of the assessee constitutes Permanent Establishment (PE) of the assessee in India on account of ‘signing, networking, planning and negotiation of offshore supply contracts in India’? If yes, whether any profit is attributable to the same, and the quantum thereof? Facts of the case: The assessee, i.e., Nokia Networks OY (formerly known as Nokia Telecommunications OY), is a company incorporated under the laws of Finland and is engaged in the manufacturing of advanced telecommunicat...