ULO Systems LLC vs DCIT

Whether the assessee, a UAE-based company, has a Permanent Establishment (PE) in India under Article 5 of the India-UAE DTAA for its grouting services and offshore supplies --- Held No. Whether offshore supplies made outside India are taxable in India --- Held No. Whether the attribution of profit at 10% of gross receipts is justified --- Held No. Whether interest under section 234B is leviable on a non-resident assessee --- Held No. Whether penalty proceedings under sections 271(1)(c) and 271B are justified --- Held No.