Review Petition allowed & judgement recalled on issue of PE & profit attribution

The judgement in Rolls Royce Singapore Pvt Ltd vs. DCIT is recalled to decide the issue whether (a) ANR, which was the agent of the assessee, could be treated as the "permanent establishment: and (b) what would be the reasonable arms’ length price in the hands of ANR/ PE which can be assesssed in India.

Rolls Royce Singapore Pvt Ltd vs. DCIT (Delhi High Court)