AAR held that ,main business and revenue earning activities of assessee carried on in and from Saudi Arabia, and monitored by Saudi Arabian Ministry.Services carried on by Indian Company in nature of support services only and not constituting main business of Non-Resident.Non-Resident retaining with itself authority to finalise marketing strategies and terms of contracts directly with customers .Indian Company cannot be held to be a  Permanent Establishment of Non-Resident. Considering the contract the AAR held that performance of service the Indian Company could not be termed as agent of the applicant , as this was done on its own behalf as per the role assigned to it .AAR also held that the applicant had given an undertaking in the question itself that the Indian company would be compensated on arm’s length basis in accordance with the Indian transfer pricing laws and legislation .