PE in India - In order to conclude that Nortel India constitutes a Dependent Agent PE, it would be...

PE in India - In order to conclude that Nortel India constitutes a Dependent Agent PE, it would be necessary for the AO to notice at least a few instances where contracts had been concluded by Nortel India in India on behalf of other group entities. In absence of any such evidence, this view could not be sustained. - HC .....

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