Bench: Shri Om Prakash Kantshri Pavan Kumar Gadale
permanent establishment in India and no business was carried out by said company in India and no services rendered by the non-resident in India except incidental supervisory services. The Ld. CIT(A) after considering the submission of the assessee rejected the finding of the Assessing Officer observing as under: 4.5. “I have gone through the observations