Japanese co. had PE in India if it's Indian Subsidiary negotiating & finalizing contractual terms on its behalf

IT/ILT : In absence of assessee, a Japanese company, furnishing any shred of credible evidence showing its direct involvement from Japan in making sales to customers in India and proving that role of its Indian subsidiary (DAIPL) was simply confined to a communication channel, inescapable conclusion was that entire activity starting from identifying customers, approaching them, negotiating prices with them and finalization of products and prices were done by DAIPL in India not only for products

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