https://www.taxtmi.com/caselaws?id=65550 Arm's length remuneration to the Indian agent exhausted any further profit attribution to the foreign enterprise where country-wise accounts showed no additional India-linked profit. The assessee's agent was paid commission at 15% for soliciting and collecting airtime advertisement revenue, and the transfer pricing material accepted that rate as arm's length. On the maintained India allocation of revenues and expenses, and in the absence of further attributable profit, estimation of income by applying a flat percentage of gross receipts was unsustainable. CBDT Circular No. 742 was held inapplicable on these facts because country-wise accounts were maintained, and no additional taxable income survived beyond the arm's length commission. en-us Fri, 15 Jan 2010 00:00:00 +0530 Fri, 22 Sep 2023 20:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=65550 Arm's length remuneration to the Indian agent exhausted any further profit attribution to the foreign enterprise where country-wise accounts showed no additional India-linked profit. The assessee's agent was paid commission at 15% for soliciting and collecting airtime advertisement revenue, and the transfer pricing material accepted that rate as arm's length. On the maintained India allocation of revenues and expenses, and in the absence of further attributable profit, estimation of income by applying a flat percentage of gross receipts was unsustainable. CBDT Circular No. 742 was held inapplicable on these facts because country-wise accounts were maintained, and no additional taxable income survived beyond the arm's length commission. Case-Laws Income Tax Fri, 15 Jan 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=65550