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HC determined that when addressing Fixed Place PE and DAPE questions, the Tribunal correctly relied on Transfer Pricing Officer's analysis. The assertion that Adobe India performed functions beyond those examined in Transfer Pricing Analysis was found unsupported by evidence. The Tribunal's conclusion that income attributable to PE had already been taxed was upheld, negating need for further assessment. Court dismissed arguments regarding Double Irish model's relevance, noting its inapplicability to income accrued in India. The Court found no merit in appellant's contention that Transfer Pricing Analysis was insufficient to determine PE attribution, as allegations of wider scope of functions lacked evidentiary support.
HC determined that when addressing Fixed Place PE and DAPE questions, the Tribunal correctly relied on Transfer Pricing Officer's analysis. The assertion that Adobe India performed functions beyond those examined in Transfer Pricing Analysis was found unsupported by evidence. The Tribunal's conclusion that income attributable to PE had already been taxed was upheld, negating need for further assessment. Court dismissed arguments regarding Double Irish model's relevance, noting its inapplicability to income accrued in India. The Court found no merit in appellant's contention that Transfer Pricing Analysis was insufficient to determine PE attribution, as allegations of wider scope of functions lacked evidentiary support.
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