The activities of the assessee are inter laced and interconnected and it cannot be said that the assessee is carrying on separate activities by visiting India from Norway on different dates for different work to refute the existence of a PE in India. They are a bundle of interconnected services giving rise to a PE under one project. Profits attributable to PE are to be computed by the AO accordingly.(AY. 2010-11)
Telenor ASA v. DCIT (2022) 215 TTJ 563 (Delhi) (Trib)
S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Service Order Forms have commercial coherence and there is one contract for providing services-Amounts to be taxed as business profits-Matter remanded to AO to compute business profits in accordance with DTAA-DTAA-India-Norway. [S. 144C, Art. 7]