Tribunal held that the employees of the assessee had been deputed to manage the affairs of the Indian entity and provide technical knowledge. Though the employees worked at the premises of T India for all practical purposes they remained employees of the assessee. The employees continued to make their social security contributions in the U. S. A. and their salaries were also distributed to their bank accounts in the U. S. A. The finding of the authorities on the issue of existence of permanent establishment of the assessee in India in terms of the Double Taxation Avoidance Agreement between India and the U. S. A. was upheld. Relie Centrica India Offshore P. Ltd. v. CIT (2014) 364 ITR 336 (Delhi) (HC).  That the issue relating to relocation expenses was to be remanded to the Assessing Officer for deciding after verification of each and every item of expense of Rs. 4,10,60,108 with a direction to include only the items of the expenses pertaining to the seconded employees.  That the issue regarding non-consideration of the global profit of the assessee for applying mark-up on the cost base and adopting an ad hoc 25 per cent. as profit attributable to the permanent establishment was remanded to the Assessing Officer, who, after verification of the documents along with the audited statements filed by the assessee in support of its claim of the global profits, was to decide the attribution of profits in accordance with article 7 of the Double Taxation Avoidance Agreement between India and the U. S. A.  That the issue of credit for tax deducted at source for amount of Rs.22,721 was to be verified by the Assessing Officer from the records of the assessee and of the Department. The assessee was directed to produce all the evidence in support before the Assessing Officer for verification and he would then after examination of the documents and evidence and data base of the Department, allow the credit for tax deducted at source in accordance with law. (AY. 2014-15)