During relevant years, assessee supplied microwave transmission equipment (including both hardware and software components) to its customers in India, being independent telecom operators. The AO  held that  a portion of profit earned by assessee attributable to aforesaid activities was taxable in India.  On appeal the Tribunal  held that  since transactions of sale of equipment’s was on principal to principal basis on assessee’s own account, unaffected by services rendered by SPCNL, said transactions would fall outside purview of section 9(1)(i).  Accordingly the addition made by the AO was deleted.  (AY. 1998-99 to 2002-03)