Income from services carried outside India which weren't attributable to PE in India couldn't be tax

IT/ILT : Where assessee, a Korea based company, received certain amount in pursuance of agreement entered into with an Indian company for carrying out certain activities within India and outside India, in absence of any material on record showing that amount received for performing activities outside India was attributable to business carried out by assessee's PE in India, in terms of articles 5 and 7 of India –Korea DTAA, 25 per cent of said revenue could not be brought to tax in India