Offshore supply of equipments not taxable in India

Brief:  The first three questions framed in the aforesaid appeals relate to the dispute whether the Assessee has a PE in India and the fourth question relates to the issue of attribution of income to the Assessee‘s alleged PE in India. Q1. Appellant had a (PE) within the meaning of Article 5 of the DTAA between India and USA? Ans: No as it doen’t includes the use of facilities solely for the purpose of storage, display, or occasional delivery of goods or merchandise belonging to the enterprise. Q2. Tribunal that the Appellant had a PE in India is perverse and contrary to the facts and mat...