Commissioner of Income Tax (TDS), vs. M/s Country Club Inda Limited

364 ITR 256 (Delhi) in support of his contention that a subsidiary of a foreign company could not be construed as its PE. He further submitted that no expatriate employee of the Assessee had visited India in connection with the Equipment Contract since the equipment was manufactured and supplied from overseas and there was no requirement to depute personnel

PR COMMR OF INCOME TAX-2, HYDERABAD vs. K RAVINDER REDDY, HYDERABAD

Bench: RAMESH RANGANATHAN,KONGARA VIJAYA LAKSHMI

364 ITR 256 (Del) ITA 621/2017 & connected matters Page 53 of 85 and confidentiality of MSAS services. We do not agree with the ruling of AAR that the stewardship activity would fall under Article 5(2)(l). To this extent we find merit in the civil appeal filed by the appellant (MSCo) and accordingly its appeal to that extent stands