Indian subsidiary is not empowered to conclude contracts nor habitually maintain stock of  inventory on  non-resident assessee. Payment of commission to Indian company for co-ordinating delivery and payment for Indian customers not implying “Habitually Securing Orders”. Indian company not economically dependent on assessee. Risk entirely with assessee. No adverse view  be taken in previous years based on same agreement — Indian company not dependent agency permanent establishment of  assessee. Remunerated by the assessee for commission activities on arm’s length basis, no further attribution was required. The Assessing Officer was directed to delete the addition. (AY.2011-12)