2007 (7) TMI 201 - SC - Income Tax

AAR was right in ruling that MSAS would be a service P.E. in India under article 5(2)(1), though only on account of the services to be performed by the deputationists deployed by applicant, MSCo and not on account of stewardship activities. As regards income attributable to the P.E. (MSAS), held that the transactional net margin method was the appropriate method for determination of the arm's length price in respect of transaction between MSCo and MSAS