Liaison Office & Land Earth Station not Constitute PE in India

Inmarsat Global Ltd. Vs DCIT (ITAT Mumbai) The issue under consideration is whether DRP is correct in considering the Liaison Office (LO) and Land Earth Station (‘LES’) constitutes a permanent establishment (PE) in India? ITAT states that, the assertions of the assessee qua the activity of the assessee and liaison office as well as the significance of the use of SSMS equipment located in India qua the services provided to VSNL clearly establishes that the same could not be construed to constitute a PE in India. The DRP, in our view, has also not referred to any specific instances i...