2007 (4) TMI 179

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..... ource - ITA 158 and 159 of 2007 - - - Dated:- 18-4-2007 - MADAN B. LOKUR and V. B. GUPTA JJ. JUDGMENT The assessee is a non company and in December, 1997, it had set up a liaison company in India, prior to which it had no presence in India. 2 The assessee entered into agreements captioned as "Consulting Agreement" with several individuals. These agreements were entered into in th .....

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..... was applicable. 5 We have also perused the agreement which has been placed on record and we find that as per clause 1, the consultancy was on a temporary basis. It appears that it was extended from time to time but that would depend upon the nature of the consultancy, which was essentially temporary. The nature of relationship is explained in clause 4 of the agreement and it is stated that th .....

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..... the assets of the company for satisfaction of any debts arising out of this agreement. The consultant agrees to indemnify and hold harmless company and its officers, directors, employees, agents, parents, subsidiaries and affiliates from and against any and all liabilities, penalties, demands and damages, including attorney's fees and costs of defence, which it may suffer or incur, arising out of .....

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