https://www.taxtmi.com/caselaws?id=217102 A non-resident's Indian permanent establishment income was required to be attributed on a cost-plus 9% arm's length basis where the income was ascertainable from the record and the transfer pricing study showed no defect; Rule 10 could not be invoked without showing that the income could not be definitely determined. Interest under section 234B was also held inapplicable because the assessee's income was fully subject to tax deduction at source, so no advance tax default arose. The additions were deleted and the appeals were allowed. en-us Fri, 27 Jul 2012 00:00:00 +0530 Sun, 20 Jan 2013 21:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=217102 A non-resident's Indian permanent establishment income was required to be attributed on a cost-plus 9% arm's length basis where the income was ascertainable from the record and the transfer pricing study showed no defect; Rule 10 could not be invoked without showing that the income could not be definitely determined. Interest under section 234B was also held inapplicable because the assessee's income was fully subject to tax deduction at source, so no advance tax default arose. The additions were deleted and the appeals were allowed. Case-Laws Income Tax Fri, 27 Jul 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=217102