

Such entities are either branches or associated enterprises of the foreign enterprise or an independent India enterprise.

……………During the last decade or so, India has seen a steady growth of outsourcing of business processes by non residents or foreign companies to IT -enabled entities in India. In such a case, the resident Indian entity could be treated as Permanent Establishment of the nonresident entity.

However, it is possible that the non -resident entity may have a business connection with the resident Indian entity.
