The AO took a view that the activities of the assessee were integrally connected to the service and installing activity undertaken by the PE in India and hence, computed assessee’s income under section 44BB. The DRP upheld view taken by the AO. The Tribunal held that Paragraph 6 of article 7 of DTAA provides that the profit attributable to the PE shall be determined by adopting the same method year on year basis unless there is good and sufficient reason to the contrary. Therefore, both the Assessing Officer and DRP having failed to provide any good and sufficient reason while departing from the methodology adopted by the department in respect of attribution of profit to the PE on receipts from offshore supply of equipment in past assessment years, the addition made by the AO invoking provisions of section 44BB was deleted.(AY. 2018-19)