Maintenance of stock of goods by the foreign enterprise at the customer’s location for standby use may not give rise to PE

Facts

• Airlines Rotables Ltd. (“assessee”) is a company incorporated under the laws of United Kingdom (“UK”). The assessee is engaged in the business of providing spares and component support for aircraft operators.
• The assessee has entered into an agreement with Jet Airways Limited (“Airline”), for rendering certain support services.
• As per the terms of the agreement,

– When a part! component of the aircraft is

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