Tribunal Rules No Permanent Establishment for US Company in India; No Income Attribution or Royalty Payments Required.

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....The assessee, a US-based company engaged in offshore sales of goods and software to customers in India, contended that it had no permanent establishment (PE) or dependent agent permanent establishment (DAPE) in India. The Assessing Officer (AO) treated the assessee's liaison office (LO) as a PE, leading to the attribution of income to India. However, the assessee provided relevant documents to substantiate the closure of the LO and the absence of expatriate employees in India during the relevant period. The Tribunal observed that the Revenue failed to rebut the assessee's contentions or provide contrary evidence regarding the closure of the LO operations. Consequently, the Tribunal held that the assessee had no PE or DAPE in India during th.........