https://www.taxtmi.com/caselaws?id=195195 A non-resident assessee could not be treated as an agent of expatriate technicians or A.P. Moller Maersk A/S under section 163 because the statutory conditions were not met. The Tribunal relied on its earlier decision on identical facts, noting that the crew supply arrangement was routed through a group company, the salary burden was not borne by the assessee, no permanent establishment in India was shown, and the department failed to establish employment or sufficient control. Applying the principle of consistency, the earlier view was followed and the Revenue's challenge failed. en-us Wed, 08 Dec 2010 00:00:00 +0530 Wed, 18 Oct 2017 15:23:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=195195 A non-resident assessee could not be treated as an agent of expatriate technicians or A.P. Moller Maersk A/S under section 163 because the statutory conditions were not met. The Tribunal relied on its earlier decision on identical facts, noting that the crew supply arrangement was routed through a group company, the salary burden was not borne by the assessee, no permanent establishment in India was shown, and the department failed to establish employment or sufficient control. Applying the principle of consistency, the earlier view was followed and the Revenue's challenge failed. Case-Laws Income Tax Wed, 08 Dec 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=195195