Assessee Not Deemed Permanent Establishment of M/s DBPL Under Production Services Agreement in India.

Production Services Agreement - Permanent Establishment (PE) in India - the contract between the two entities was primarily that of a principal and agent. - M/s DBPL was acting as an independent entity which was required to carry out the assigned work independently and the assessee could not said to be PE of that entity in India. - AT .....

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