PE – Where assessee, a China based company, engaged in sales of telecom equipments, supplied equipment and handsets to its Indian subsidiary, since assessee was conducting its business in India with active involvement of employees of its Indian subsidiary and employees of Indian subsidiary along with employees of assessee had jointly prepared bidding documents for contract, negotiated and concluded contract on behalf of assessee with its Indian customer, said Indian subsidiary constituted fixed place PE, installation PE, service PE and dependent agent PE of the assessee.
Huawei Technologies Co. Ltd. v. ACIT – [2023] 149 taxmann.com 77 (Delhi – Trib.).