https://www.taxtmi.com/caselaws?id=200915 Accepted arm's length pricing of an international transaction was treated as sufficient to exhaust further attribution of profits in India, even where a permanent establishment was alleged. On that basis, no additional income could be taxed in India merely because the assessee was said to have a permanent establishment, since the cross-border transaction had already been remunerated at arm's length. The principle applied was that profits attributable to a permanent establishment cannot again be brought to tax where the related transaction has already been benchmarked at arm's length. The matter was decided in favour of the assessee. en-us Fri, 17 Nov 2017 00:00:00 +0530 Tue, 01 May 2018 05:20:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=200915 Accepted arm's length pricing of an international transaction was treated as sufficient to exhaust further attribution of profits in India, even where a permanent establishment was alleged. On that basis, no additional income could be taxed in India merely because the assessee was said to have a permanent establishment, since the cross-border transaction had already been remunerated at arm's length. The principle applied was that profits attributable to a permanent establishment cannot again be brought to tax where the related transaction has already been benchmarked at arm's length. The matter was decided in favour of the assessee. Case-Laws Income Tax Fri, 17 Nov 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=200915