Franchise commission earned by 'Dominos' from Indian co. not taxable as business income in absence of its PE

IT/ILT: Where assessee, US company, entered into Master Franchise Agreement (MFA) with Indian company (Jubilant) for franchise of Dominos Pizza Store and provided certain store/consultancy services to Jubilant and, assessee was entitled to charge 3 per cent of sales of store of Jubilant, since profit and loss from business belonged to Jubilant and no activities were carried out by jubilant on behalf of assessee, Jubilant did not constitute a Permanent Establishment of assessee in India

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