Tribunal held that, No evidence had been brought on record to demonstrate as to how customers in India were approaching assessee in Japan to discuss and finalize their requirements and prices. In absence of assessee furnishing any shred of credible evidence showing its direct involvement from Japan in making sales to customers in India and proving that role of DAIPL was simply confined to a communication channel, entire activity starting from identifying customers, approaching them, negotiating prices with them and finalization of products and prices were done by DAIPL in India not only for products sold directly by them as distributor, but also for which assessee was claiming to have made direct sales. As the DAIPL was dependent agent PE of assessee in India and estimation of rate of net profit at 10 per cent was reasonable and amount of net profit attributable to marketing activities carried out in India would be 30 per cent of amount of net profit relatable to sales in India. ( AY.2006-07)