https://www.taxtmi.com/caselaws?id=294242 Where the Indian associated enterprise had already been compensated at arm's length for the relevant cross-border transactions, no further profit attribution to the foreign enterprise was permissible merely because an Indian permanent establishment was alleged for the same activity. The Tribunal applied the settled principle that arm's length remuneration to the Indian entity exhausts the attribution exercise in relation to those transactions and followed the earlier decision in the assessee's own case. On that basis, the addition made by the Assessing Officer could not survive and was deleted. en-us Tue, 05 Nov 2019 00:00:00 +0530 Wed, 31 Mar 2021 02:08:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=294242 Where the Indian associated enterprise had already been compensated at arm's length for the relevant cross-border transactions, no further profit attribution to the foreign enterprise was permissible merely because an Indian permanent establishment was alleged for the same activity. The Tribunal applied the settled principle that arm's length remuneration to the Indian entity exhausts the attribution exercise in relation to those transactions and followed the earlier decision in the assessee's own case. On that basis, the addition made by the Assessing Officer could not survive and was deleted. Case-Laws Income Tax Tue, 05 Nov 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=294242