Oracle India P. Ltd. not permanent establishment of Oracle Systems Corporation

Oracle Systems Corporation Vs ADIT (ITAT Delhi) ITAT Delhi held that Oracle India Private Limited is an independent legal entity and existence of Oracle India Private Limited cannot be considered as permanent establishment of Oracle Systems Corporation. Hence, there is not question of attribution of profit to Permanent Establishment. Facts- the assessee entered into a Software Support Service Agreement dated 1st June, 2003 with its 100% subsidiary in India namely Oracle India Pvt. Ltd., wherein the assessee has received royalty by way of 56% of the revenue transfers received by the Oracle Ind...