https://www.taxtmi.com/news?id=1029 Withdrawal of cited circulars eliminates an administrative safe harbour and permits broader attribution of income to foreign parents under Section 9-style income sourcing rules by treating BPOs as a business connection. Arms length payments will no longer automatically prevent assessments of income deemed to arise from Indian activities. The step also removes related protections for export commission and agency remuneration, enhancing the tax authority's ability to claim profits attributable to on shore service operations and increasing transfer pricing and permanent establishment exposure for foreign companies. en-us Sat, 24 Oct 2009 12:06:01 +0530 Sat, 24 Oct 2009 12:06:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/news?id=1029 Withdrawal of cited circulars eliminates an administrative safe harbour and permits broader attribution of income to foreign parents under Section 9-style income sourcing rules by treating BPOs as a business connection. Arms length payments will no longer automatically prevent assessments of income deemed to arise from Indian activities. The step also removes related protections for export commission and agency remuneration, enhancing the tax authority's ability to claim profits attributable to on shore service operations and increasing transfer pricing and permanent establishment exposure for foreign companies. News - Sat, 24 Oct 2009 12:06:01 +0530 https://www.taxtmi.com/news?id=1029