The Income Tax Appellate Tribunal (ITAT) delivered its decision on 14 August 2013 in the case of ADIT v. Oy Sisu AB [2013] 38 taxmann.com 81 (Mumbai - Trib.) on the determination of a permanent establishment (PE). (a) Facts. The Taxpayer (i.e. Oy Sisu AB) was a company incorporated in Finland. The Taxpayer had executed a contract with NhavaSheva Port Trust (NSPT) for the supply of tractors and trailers. The total scope of work as per the contract included manufacture, transportation and delivery of equipment to NSPT. The tractors supplied to NSPT were manufactured in Finland by the Taxpayer and...