Tribunal held that  there is nothing to demonstrate that the assessee has carried out any activity, either wholly or partly in relation to sale of software licence through the alleged PE in India so as to satisfy the conditions of art. 5(1) r/w art. 5(2) of the tax treaty.  The income relating to the sale of software licence is not taxable    no part of such income can be attributed to the PE. Additional ground being mixed question of fact and law is not a question of law.  (AY.  2018-19,  2019-20)