Group Cos negotiating/securing contracts on behalf of foreign Co. would be deemed as service PE in I

IT/ILT : Where assessee, a US based company, entered into contract with an Indian company for supply, installation, testing and commissioning of equipment relating to GSM Cellular Radio Telephone System, in view of fact that a group company namely 'NL' India undertook responsibility for negotiating and securing contracts whereas another group company namely 'NL' Canada supplied aforesaid equipments and its LO in India rendered other services to assessee, those group concerns constituted assessee