- (1.) In the aforesaid matters, the Dispute Resolution Panel (DRP) has found that there is no permanent establishment (PE) in India. Consequently, the Assessing Officer has passed orders dropping the proceedings. Accordingly, we pass the same order as was passed in C.A. No.19659/2017 (The Principal Officer, Honda Access Asia and Oceania Co. Ltd. Vs. Asst. Director of Income Tax, Noida & Ors.) and other connected matters on 23.11.2017, viz. "Leave granted. In view of the fact that the Dispute Resolution Panel has found that there is no permanent establishment in India, the judgment of the High Court is set aside and the appeals are allowed accordingly."
(2.) Ordered accordingly.;