https://www.taxtmi.com/caselaws?id=398803 A dependent agency permanent establishment could not be inferred because the Indian entity lacked authority to conclude contracts, did not maintain stock, and was not shown to habitually secure orders; mere economic dependence or substantial revenue was insufficient without the treaty conditions being met, so the PE allegation failed. Where the transfer pricing analysis had already examined the Indian entity's functions on an arm's length basis and no adverse inference arose, no additional profit attribution to the foreign enterprise was warranted on a presumed PE basis, so further attribution was rejected. The additions on PE and profit attribution were deleted. en-us Tue, 22 Sep 2020 00:00:00 +0530 Wed, 23 Sep 2020 17:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=398803 A dependent agency permanent establishment could not be inferred because the Indian entity lacked authority to conclude contracts, did not maintain stock, and was not shown to habitually secure orders; mere economic dependence or substantial revenue was insufficient without the treaty conditions being met, so the PE allegation failed. Where the transfer pricing analysis had already examined the Indian entity's functions on an arm's length basis and no adverse inference arose, no additional profit attribution to the foreign enterprise was warranted on a presumed PE basis, so further attribution was rejected. The additions on PE and profit attribution were deleted. Case-Laws Income Tax Tue, 22 Sep 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=398803