Court :
Tribunal
Brief :
Held that since the subsidiary co. did not have the authority to negotiate or enter into contracts on behalf of the foreign principal, it could not be held to be Permanent Establishment of the foreign co. in India and since, assessee did not have any PE in india, no income can be deemed to accrue or arise in India.
Citation :
Rolls Royce Pl. Vs. Asstt. Dir. I.T.
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