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<h1>Appeals Allowed: No Permanent Establishment Found in India</h1> The SC allowed the appeals, overturning the HC judgment, as no permanent establishment in India was found by the Dispute Resolution Panel. - TMI Permanent establishment - Dispute Resolution Panel finding - judicial acceptance of administrative finding and setting aside of High Court orderPermanent establishment - Dispute Resolution Panel finding - The Dispute Resolution Panel's finding that the assessee did not have a permanent establishment in India was accepted, leading to setting aside of the High Court judgment and allowance of the appeals. - HELD THAT: - The Supreme Court noted the Dispute Resolution Panel had found there was no permanent establishment in India. On that basis the Court set aside the judgment of the High Court which had reached a contrary conclusion, and allowed the appeals. The outcome rests on acceptance of the administrative finding by the Dispute Resolution Panel that no permanent establishment existed in India.High Court judgment set aside and appeals allowed on the basis that there was no permanent establishment in India as found by the Dispute Resolution Panel.Final Conclusion: The appeals are allowed; the High Court judgment is set aside because the Dispute Resolution Panel's finding of absence of a permanent establishment in India was accepted. The Supreme Court of India allowed the appeals as the Dispute Resolution Panel found no permanent establishment in India, setting aside the High Court judgment. (Citation: 2017 (11) TMI 1922 - SC Order)