Section 44BB has no application in absence of Permanent Establishment

Baker Hughes Energy Technologies UK Ltd Vs ACIT (ITAT Delhi) ITAT Delhi held that in absence of a Permanent Establishment, provisions of section 44BB of the Income Tax Act has no application. Facts- The assessee, Baker Hughes Energy Technology UK Limited, is a company incorporated in, and a tax resident of, United Kingdom (UK). It is a part of Baker Hughes Group of companies. The assessee along with four other consortium members was awarded a contract by ONGC on 05.11.2018. It was contended by the assessee before the AO that the offshore manufacture and supply of equipment and parts to ONGC is...