https://www.taxtmi.com/caselaws?id=239018 Dealer's commission relating to earlier years was deductible only if the liability had accrued and crystallised in the relevant year; where the expenditure matched earlier sales and no contractual basis showed deferred accrual, the liability was not treated as crystallised. On permanent establishment, the Indian branch was described as an independent contractor performing liaison, marketing support and post-sale functions without authority to conclude contracts, stock holding or entrepreneurial risk, so dependent agent PE conditions were not met. In the absence of a PE, the force of attraction rule was inapplicable and additional profit attribution to India was unsustainable. en-us Wed, 27 Feb 2013 00:00:00 +0530 Thu, 14 May 2026 11:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=239018 Dealer's commission relating to earlier years was deductible only if the liability had accrued and crystallised in the relevant year; where the expenditure matched earlier sales and no contractual basis showed deferred accrual, the liability was not treated as crystallised. On permanent establishment, the Indian branch was described as an independent contractor performing liaison, marketing support and post-sale functions without authority to conclude contracts, stock holding or entrepreneurial risk, so dependent agent PE conditions were not met. In the absence of a PE, the force of attraction rule was inapplicable and additional profit attribution to India was unsustainable. Case-Laws Income Tax Wed, 27 Feb 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=239018