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 not in a condition to be used, the assessee is required to repair and overhaul the component! part. The repair and overhauling of defective part! components is to be don...