Motorola, Ericsson and Nokia dispute PE decisiona

Abstract

The special bench of the tribunal has examined issues relating to permanent establishments in India and the taxability of profits on offshore supply in response to an appeal by three foreign telecom suppliers, Motorola, Ericsson and Nokia. In this case two companies had 100% subsidiaries in India. The third company had a branch for the first three months and later a 100% subsidiary of a group company in India.