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of ITAT held that Revenue failed to establish foreign assessee's permanent establishment (PE) in India for software-based information security solutions income. The burden of proving PE existence lies initially on Revenue per E-Funds IT Solution Inc. precedent. Tax authorities provided insufficient material evidence regarding agency agreements between parties. Email records and travel itineraries were deemed inadequate proof. The Tribunal distinguished Daikin Industries Ltd., noting the Indian entity there acted as distributor, unlike present case. Reliance on Rolls Royce Singapore was misplaced as that involved factual DAPE findings requiring remand. ITAT concluded the Indian entity merely provided marketing support services, not constituting dependent agent PE, ruling in favor of foreign assessee.
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