Employees of foreign enterprise working under control of Indian subsidiary can’t constitute its serv

IT/ILT: Indian subsidiary providing back office services to foreign enterprise shall not be deemed as its PE merely because it is being indirectly controlled by it - Employees of foreign enterprise working for domestic operation of and under control and supervision of Indian subsidiary do not constitute service PE of foreign enterprise - Assets of Indian subsidiary cannot be deemed inevitably to be used by foreign enterprise for its business carried on in India to establish its fixed PE in India