Telenor ASA v. Dy. CIT (IT) (2021) 129 taxmann.com 198 / (2022) 215 TTJ 563 (Delhi)(Trib.)

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Business service agreement (BSA)-Activities are interconnected-Matter was remanded-DTAA-India-Norway. [Art. 5(2)(1)]

Tribunal held that the activities of assessee with regard to recipients for services were inter-connected, inter-laced and sequential technical services.  The receipts being based on unified agreement and consolidated billing pattern, activities being inter-related, existence of PE of assessee was undeniable and issue of determination of profits was remanded back to file of Assessing Officer. (AY. 2010-11)