Sales incentives to employees establish LO promotional activities in India; treated as PE of foreign

IT/ILT: Foreign Company established a LO in India - Performance of employees of LO was determined by number of direct orders received by them - Employees were also entitled to sales incentives for these orders - Such incentive plans established that LO was not engaged merely in preparatory or auxiliary activities - Its activities extended to marketing activities as well - Therefore, it would be treated as PE of foreign company and the income attributable to LO activities would be taxable in Indi