The assessee, a tax resident of Thailand, which is  engaged in the business of manufacturing of train control and signalling systems for mass transit system. In terms with the contract, the assessee made offshore supply of goods and equipments to DMRC from outside India and received certain amount of consideration for such supply. The Assessing Officer  held that  the assessee had a service PE in India, through which, it executed the contract. Accordingly, out of the receipts from offshore supplies, the Assessing Officer attributed 10 per cent of the total receipts as profits of the PE and accordingly, brought to tax same. the DRP upheld the view taken by the Assessing Officer. On appeal the Tribunal held that, that  the assessee did not have any place of business in India and all business activities with respect to offshore supplies were carried outside India.  Equipment supply had been manufactured at overseas manufacturing facility of assessee and sale of equipment had occurred outside India and payment had also been received by assessee outside India.Therefore, addition made by Assessing Officer is   deleted.  (AY. 2020-21)