https://www.taxtmi.com/caselaws?id=359404 Where the assessee's associated-enterprise transactions had already been accepted at arm's length, no further profit attribution to an Indian permanent establishment was warranted for the functions and risks so compensated. The transfer pricing analysis was treated as exhausting attribution of income in India on that footing, so additional taxation on a PE basis was not justified. Interest under section 234B was only consequential to that primary attribution question and fell away with the main finding. en-us Mon, 23 Apr 2018 00:00:00 +0530 Sun, 29 Apr 2018 21:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=359404 Where the assessee's associated-enterprise transactions had already been accepted at arm's length, no further profit attribution to an Indian permanent establishment was warranted for the functions and risks so compensated. The transfer pricing analysis was treated as exhausting attribution of income in India on that footing, so additional taxation on a PE basis was not justified. Interest under section 234B was only consequential to that primary attribution question and fell away with the main finding. Case-Laws Income Tax Mon, 23 Apr 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=359404