https://www.taxtmi.com/caselaws?id=374407 The Tribunal held that the remuneration paid by the appellant to ESPN India was at arm's length, as accepted by the Transfer Pricing Officer. Therefore, no further attribution of profits was required. The Tribunal referred to precedents, including DIT vs. Morgan Stanley & Co., establishing that if the agent is remunerated at arm's length, no additional profit can be attributed to the Permanent Establishment (PE). Consequently, the Tribunal directed the deletion of the addition made on account of attribution of profit. The appeals for both Assessment Years 2003-04 and 2004-05 were allowed, with the order pronounced on 20th August 2018. 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 The Tribunal held that the remuneration paid by the appellant to ESPN India was at arm's length, as accepted by the Transfer Pricing Officer. Therefore, no further attribution of profits was required. The Tribunal referred to precedents, including DIT vs. Morgan Stanley & Co., establishing that if the agent is remunerated at arm's length, no additional profit can be attributed to the Permanent Establishment (PE). Consequently, the Tribunal directed the deletion of the addition made on account of attribution of profit. The appeals for both Assessment Years 2003-04 and 2004-05 were allowed, with the order pronounced on 20th August 2018. Case-Laws Income Tax Mon, 20 Aug 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=374407