Held, that the Dispute Resolution Panel had fallen in factual error in mentioning the plea of the assessee that the issue of dependent agent permanent establishment of the assessee in India had been considered by the Tribunal in the assessment years 2018-19 and 2019-20. With regard to the fixed place permanent establishment of the assessee the issue was settled in favour of the assessee. The Dispute Resolution Panel had erred in not dealing with the issue of the assessee-company having a dependent agent permanent establishment in India on the merits and erroneously directed the Assessing Officer to verify if the issue of dependent agent permanent establishment was decided in favour of the assessee by the Tribunal in the assessment years 2018-19 and 2019-20, which admittedly was not covered in the earlier years.  The order of the Dispute Resolution Panel with regard to examination of the question of existence of dependent agent permanent establishment in the relevant assessment year and resultantly the final assessment order were to be set aside. (AY.2021-22)