https://www.taxtmi.com/caselaws?id=327747 The court held that Adobe India did not constitute a Permanent Establishment (PE) of Adobe Systems Incorporated under the Indo-US Double Taxation Avoidance Agreement. Even if Adobe India was considered the Assessee's PE, the income had already been taxed at Arm's Length Prices. The court set aside the notices issued by the Assessing Officer, finding no basis to believe that the Assessee's income had escaped assessment. The court ruled in favor of the Assessee, concluding that the AO's opinion on the PE status lacked merit. en-us Mon, 16 May 2016 00:00:00 +0530 Wed, 18 May 2016 08:32:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=327747 The court held that Adobe India did not constitute a Permanent Establishment (PE) of Adobe Systems Incorporated under the Indo-US Double Taxation Avoidance Agreement. Even if Adobe India was considered the Assessee's PE, the income had already been taxed at Arm's Length Prices. The court set aside the notices issued by the Assessing Officer, finding no basis to believe that the Assessee's income had escaped assessment. The court ruled in favor of the Assessee, concluding that the AO's opinion on the PE status lacked merit. Case-Laws Income Tax Mon, 16 May 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=327747