Dismissing the appeal   of the revenue the Court held that ;the Tribunal was right in holding that the Indian branches or offices of the assessee and their activities could not be regarded as permanent establishments of the assessee in India and the income directly or indirectly attributable to these branches or offices was not taxable in India, that the assessee did not have any permanent establishment in India and its income from business turnover or imports in India was exempt in India in view of the Double Taxation Avoidance Agreement between India and Japan and that the burden of proof had shifted to the authorities. (AY. 2001-02)