Court Rules CIS as Permanent Establishment for Assessee in India; Assets Provided Without Cost Confirm PE Status.

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....Determination of fixed place of permanent establishment of assessee in India - CIS was practically the projection of assessee’s business in India and carried out its business under the control and guidance of the assessee and without assuming any significant risk in relation to such functions. Besides assessee has also provided certain hardware and software assets on free of cost basis to CIS. - Existence of PE established - AT....