Permanent establishment profits require no further attribution...

Permanent establishment profits require no further attribution where arm's length remuneration of the Indian associated enterprise fully accounts for the multinational group's Indian functions, assets and risks, even if a dependent agency permanent establishment exists. A unilateral advance pricing agreement covering marketing support binds its applicant and the tax department for the covered transactions and years, although it does not bind the foreign enterprise. Interest under section 234B is mandatory and consequential. A challenge to the initiation of penalty proceedings under section 270A is premature at the initiation stage.