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 Establishment in India. The appellant’s claim is that it had supplied the equipment at Port in Sweden and their income is not liable to tax in India as per provisions of the Act and also the Indo-Swe...