Tribunal held that ,profit earned from offshore supply of installation and commissioning activities of equipments relatable to operations carried out in India is held to be taxable since it had supervisory Permanent establishment in India .( AY.2013-14)
Shanghai Electric Group Co .Ltd v. Dy.CIT ( 2018) 170 ITD 34 /165 DTR 225 ( Delhi) (Trib)
S.9(1)(i): Income deemed to accrue or arise in India – Business connection -Profit earned from offshore supply of installation and commissioning activities of equipments relatable to operations carried out in India is held to be taxable since it had supervisory Permanent establishment in India – DTAA- India- China [ Art. 5 ]