https://www.taxtmi.com/caselaws?id=6568 Back office operations and stewardship activities did not create a permanent establishment because they were preparatory, auxiliary, or supervisory in character, and no agency permanent establishment arose where contracts were not concluded in India. However, deputed employees who retained lien with the foreign enterprise and rendered services in India did give rise to a service permanent establishment. For attribution, transactional net margin method was accepted as the appropriate transfer pricing method for the service permanent establishment, and arm's length remuneration could substantially exhaust further profit attribution only if it fully reflected the functions performed and risks assumed. Further attribution was therefore not barred in principle, but depended on the completeness of the arm's length analysis. en-us Mon, 09 Jul 2007 00:00:00 +0530 Sat, 30 May 2026 13:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6568 Back office operations and stewardship activities did not create a permanent establishment because they were preparatory, auxiliary, or supervisory in character, and no agency permanent establishment arose where contracts were not concluded in India. However, deputed employees who retained lien with the foreign enterprise and rendered services in India did give rise to a service permanent establishment. For attribution, transactional net margin method was accepted as the appropriate transfer pricing method for the service permanent establishment, and arm's length remuneration could substantially exhaust further profit attribution only if it fully reflected the functions performed and risks assumed. Further attribution was therefore not barred in principle, but depended on the completeness of the arm's length analysis. Case-Laws Income Tax Mon, 09 Jul 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6568