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Profit attribution to an Indian permanent establishment in cross-border M&A deals depended on the actual functions performed by each branch. The Tribunal noted that the assessee's model first split deal revenue between origination and execution, then allocated it according to each branch's role; email evidence showed active UK team involvement in execution, and the department's acceptance of substantial origination revenue allocation to overseas branches in the same deals supported that approach. The rejection of shared execution revenue was therefore unsustainable, and the addition attributed entirely to the Indian PE was deleted. The MAT credit claim was not decided on merits and was restored for factual verification and grant in accordance with law.
Profit attribution to an Indian permanent establishment in cross-border M&A deals depended on the actual functions performed by each branch. The Tribunal noted that the assessee's model first split deal revenue between origination and execution, then allocated it according to each branch's role; email evidence showed active UK team involvement in execution, and the department's acceptance of substantial origination revenue allocation to overseas branches in the same deals supported that approach. The rejection of shared execution revenue was therefore unsustainable, and the addition attributed entirely to the Indian PE was deleted. The MAT credit claim was not decided on merits and was restored for factual verification and grant in accordance with law.
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