AO assessed  in its entirety as permanent establishment of assessee, also agency PE as place of management for Southeast operations and also service PE which was affirmed by DRP. On appeal Tribunal held that  there was seamless information exchange between employees of assessee and expat employees, however such information exchange related to models/designs to liking of Indian consumers, plans and strategies relating to sale of products, detailed stock/logistical status, market strategies both mid and long terms etc. None of statement showed that any activity of global business management (GBM) had ever been conducted in India or market survey conducted in India had nothing to do with business of Indian subsidiary.  Accordingly in absence of proof as to any management activity of assessee being conducted in India it could not be held that through expatriate employees assessee was conducting business of assessee in India. There was no fixed place PE of assessee constituted through expatriated employees.  Tribunal also held that as there was no business activity that was conducted by assessee through expatriate employees, thus question of estimated income did not arise and consequently liability of assessee to deduct tax at source  or interest liability u/s 234 A and  234B  also did not arise. (AY. 2004 -09 to 2014-15)