Assessing Officer Must Prove Nortel India Finalized Contracts to Establish Dependent Agent Permanent Establishment Status. https://www.taxtmi.com/highlights?id=29126 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 en-us Tue, 10 May 2016 11:32:24 +0530 Tue, 10 May 2016 11:32:24 +0530 TaxTMI RSS Generator Assessing Officer Must Prove Nortel India Finalized Contracts to Establish Dependent Agent Permanent Establishment Status. https://www.taxtmi.com/highlights?id=29126 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 Highlights Income Tax Tue, 10 May 2016 11:32:24 +0530 https://www.taxtmi.com/highlights?id=29126