Profit attribution not permissible in absence of PE in India

ACIT Vs Ericsson, AB Sweden (ITAT Delhi

GSM supplied to various cellular companies in India – appellant has no business connection and no PE in India – attribution of profit not possible.

Facts-

The main business of appellant is supply of GSM System to various cellular companies operating in India.

The main issue involved is whether appellant has business connection and exposure to Permanent Establ

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