J U D G M E N T

YASHWANT VARMA, J.

1. This set of appeals give rise to the following four principal questions: -

(A) Whether the assessee in the concerned Assessment Years, [AY]

had a Fixed Place Permanent Establishment, [PE] in India?

(B) Whether Nokia India Private Limited, [NIPL], a wholly owned subsidiary of the assessee constituted a Dependent Agent Signature Not Verified

Digitally Signed ITA 785/2019 & other connected matters Page 4 of 66

Permanent Establishment, [DAPE] of the assessee?

(C) Whether interest from delayed consideration of supply of equipment and licensing of software was taxable in the hands of the assessee as interest earned from vendor financing?

(D) Whether the revenue from supply of software could be classified as royalty or fee for technical services under the Income Tax Act, 1961, [Act] read along with the India-Finland Double Taxation Treaty, [DTAA]

2. Mr. Bhatia and Mr. Mann, learned counsels who appeared for the appellants, had placed for our consideration the following chart which delineates the questions which arise in each of these appeals and also encapsulates details of the AYs to which they pertain. That chart is extracted hereinbelow: -

Signature Not Verif