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Transactions between the assessee and its Indian dependent agent permanent establishments having been accepted at arm's length after transfer pricing proceedings, no further profit attribution to the PE was permissible under the treaty principle applied by the Tribunal, and the related addition was deleted. On the refund interest claim, the Tribunal did not decide the entitlement on merits and instead directed factual verification by the Assessing Officer in accordance with law, with disposal based on that verification.
Transactions between the assessee and its Indian dependent agent permanent establishments having been accepted at arm's length after transfer pricing proceedings, no further profit attribution to the PE was permissible under the treaty principle applied by the Tribunal, and the related addition was deleted. On the refund interest claim, the Tribunal did not decide the entitlement on merits and instead directed factual verification by the Assessing Officer in accordance with law, with disposal based on that verification.
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