https://www.taxtmi.com/caselaws?id=386818 Where related-party remuneration for the Indian subsidiary was accepted as arm's length, no further profits could be attributed to the foreign enterprise's alleged Indian permanent establishment on the same income stream. The ITAT followed its earlier order in the assessee's own case and treated the arm's length pricing as sufficient to rule out additional attribution of income in India. The Tribunal also noted that the subsidiary's profitability exceeded the benchmark later reflected in the APA, which supported the conclusion that no further adjustment was justified. The addition for profit attribution was deleted in favour of the assessee, while the penalty ground did not yield substantive relief. en-us Tue, 11 Jun 2019 00:00:00 +0530 Wed, 09 Oct 2019 07:36:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=386818 Where related-party remuneration for the Indian subsidiary was accepted as arm's length, no further profits could be attributed to the foreign enterprise's alleged Indian permanent establishment on the same income stream. The ITAT followed its earlier order in the assessee's own case and treated the arm's length pricing as sufficient to rule out additional attribution of income in India. The Tribunal also noted that the subsidiary's profitability exceeded the benchmark later reflected in the APA, which supported the conclusion that no further adjustment was justified. The addition for profit attribution was deleted in favour of the assessee, while the penalty ground did not yield substantive relief. Case-Laws Income Tax Tue, 11 Jun 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=386818