YRIPL & YRMPL do not constitute DAPE or PE of Yum! Restaurants in India

DDIT Vs Yum! Restaurants (Asia) Pte. Ltd. (ITAT Delhi) The issue which is arising in the present appeal is whether there is DAPE. The Assessing Officer has alleged the existence of DAPE on account of alleged marketing activities undertaken by Indian entity on behalf of the assessee company. The case of the assessee before us is that it is an entity in Singapore and has entered into TLA with only YRIPL, which was in charge of operations of Pizza Hut & KFC restaurants in India. In order to run its business, YRIPL had franchised different outlets and was also running own stores. Yum! Restaura...