https://www.taxtmi.com/caselaws?id=407978 Where a dependent agency permanent establishment is alleged, no further profit can be attributed to the foreign enterprise if the Indian agent is remunerated at arm's length. The Tribunal applied binding jurisdictional precedent on profit attribution in a DAPE situation and noted that the transfer pricing order had accepted the arm's length nature of the agent's remuneration, with no deficiency shown. As the basic taxability arising from the alleged DAPE failed, no additional income was taxable in India in the hands of the foreign enterprise, and the related issues on royalty treatment, attribution, double taxation and interest became academic. en-us Mon, 03 May 2021 00:00:00 +0530 Fri, 28 May 2021 08:38:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=407978 Where a dependent agency permanent establishment is alleged, no further profit can be attributed to the foreign enterprise if the Indian agent is remunerated at arm's length. The Tribunal applied binding jurisdictional precedent on profit attribution in a DAPE situation and noted that the transfer pricing order had accepted the arm's length nature of the agent's remuneration, with no deficiency shown. As the basic taxability arising from the alleged DAPE failed, no additional income was taxable in India in the hands of the foreign enterprise, and the related issues on royalty treatment, attribution, double taxation and interest became academic. Case-Laws Income Tax Mon, 03 May 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=407978