Counsel stated that the limited issue for consideration in the present appeal is the rate of attribution of profits to assessee’s PE in India. Special Counsel, thus, prayed for upholding findings of the AO in attributing 15% to assessee’s PE in India. AY 2015-16 and 2016-17 same percentage of profit attribution to the assessee’s PE in India were adopted. In the impugned assessment year, the AO increased the rate of attribution of profit to assessee’s PE in India from 8.75% to 15%. The rate of attribution of profit to assessee’s PE in India is required to be enhanced to compensate for the additional activities carried out by the PE in India.