Ulo Systems Llc vs Deputy Commissioner Of Income TaxInternational Taxation)

Whether the assessee, ULO Systems LLC, has a Permanent Establishment (PE) in India under Article 5 of the India-UAE DTAA, making its income from offshore supplies and grouting services taxable in India --- Held No; Whether the Assessing Officer erred in estimating taxable income at 10% of gross revenues and in levying interest under section 234B and initiating penalty proceedings --- Held Yes, in favor of the assessee.