https://www.taxtmi.com/caselaws?id=374407 An Indian representative was found to have been adequately remunerated at arm's length for soliciting advertisements and collecting advertisement revenue, so no further profit attribution to the foreign enterprise in India could be sustained. The accepted commission for the intermediary exhausted the taxable profit element arising from those functions, and the authorities' adjustment was deleted. Once that principle was applied, the question whether the Indian entity constituted a dependent agent permanent establishment or a fixed place permanent establishment did not require determination. en-us Mon, 20 Aug 2018 00:00:00 +0530 Fri, 01 Feb 2019 07:29:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=374407 An Indian representative was found to have been adequately remunerated at arm's length for soliciting advertisements and collecting advertisement revenue, so no further profit attribution to the foreign enterprise in India could be sustained. The accepted commission for the intermediary exhausted the taxable profit element arising from those functions, and the authorities' adjustment was deleted. Once that principle was applied, the question whether the Indian entity constituted a dependent agent permanent establishment or a fixed place permanent establishment did not require determination. Case-Laws Income Tax Mon, 20 Aug 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=374407