https://www.taxtmi.com/caselaws?id=359701 The SC held that where arm's length principle has been satisfied in tax assessments, no additional profit can be attributed to a person despite having a permanent establishment in India. The court relied on its previous decision in Assistant Director of Income Tax-I v. E-Funds IT Solution Inc., establishing that compliance with arm's length pricing procedures precludes further profit attribution. The reassessment notice issued solely on grounds of permanent establishment in India was deemed unsustainable when arm's length price procedure had already been followed. The appeals were allowed, confirming that proper adherence to arm's length principles provides complete protection against additional profit attribution claims based merely on permanent establishment existence. en-us Wed, 14 Mar 2018 00:00:00 +0530 Mon, 27 Apr 2026 15:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=359701 The SC held that where arm's length principle has been satisfied in tax assessments, no additional profit can be attributed to a person despite having a permanent establishment in India. The court relied on its previous decision in Assistant Director of Income Tax-I v. E-Funds IT Solution Inc., establishing that compliance with arm's length pricing procedures precludes further profit attribution. The reassessment notice issued solely on grounds of permanent establishment in India was deemed unsustainable when arm's length price procedure had already been followed. The appeals were allowed, confirming that proper adherence to arm's length principles provides complete protection against additional profit attribution claims based merely on permanent establishment existence. Case-Laws Income Tax Wed, 14 Mar 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=359701