Assessee, a US-based company, is engaged in the supply of software products. The Assessing Officer held that the assessee had a Dependent Agency Permanent Establishment (DAPE) in India thus, revenue from the supply of software would be business income taxable in India. On appeal following the order of earlier year, it was held that the existence of dependent agency would be wholly tax neutral and impugned additions made by Assessing Officer were to be deleted. (AY. 2017-18)