Assessee, a tax resident of Germany, was engaged in business of manufacturing and selling of cars. Assessee appointed an entity as a sole distributor of cars in India. AO held that in view of section 9(1)(1) read with Art 5 of DTAA between India and German held that taxable in India.  Tribunal held that as the business was done Principal to Principal basis  provision of section 9(1)(i) read with Article 5 of India German Treaty is held to be not applicable.     (AY. 2014-15)