AdvertisementHonda Trading Asia Company Ltd. Vs DCIT (ITAT Delhi) Delhi ITAT: No Permanent Establishment in India for Honda Trading Asia; TP Adjustments Collapse as Offshore Supplies Escape Indian Tax The Delhi ITAT allowed the appeals of Honda Trading Asia Company Ltd., Thailand, holding that the assessee did not have a Permanent Establishment (PE) in India under the India–Thailand DTAA. The Revenue had sought to tax the assessee by alleging that expatriate employees working with Honda Cars India Ltd. (HCIL) were effectively carrying on the assessee’s business in India, thereby constituting a fixe...