Storage and Supply of goods in India through an independent third party gives rise to fixed place permanent establishment in India

Facts

• The applicant, a company incorporated in Singapore, is engaged in the business of manufacture and sale of Hard Disk Drives.
• The applicant supplies disks to original equipment manufacturers (OEM) in India. In order to minimise the delays in procurement of inputs, OEM proposed a Vendor Managed Inventory (VMI) model.Pursuant to the VMI model, the applicant would enter into agreements with Independent Service Providers (ISP) in India who will be required to stock Disks in India on behalf of the applicant and deliver the same to OEM in „just-in­time^? basis. The VMI model will operate as under:

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