Income from resale of goods bought from holding co. not taxable if its subsidiary won’t constitute i

IT/ILT : Where assessee, purchased raw materials and spares from its holding company located abroad, in view of fact that assessee did not constitute agency PE of holding company in India, no taxable income accrued to holding company on account of sales in India and, thus, assessee was not liable to deduct tax at source while making payments to holding company