https://www.taxtmi.com/caselaws?id=419798 Where the Indian associated enterprise was already remunerated at arm's length for the functions performed, assets employed and risks assumed, no further profit could be attributed to the foreign enterprise on account of a dependent agency permanent establishment. The transfer pricing analysis had accepted the international transactions at arm's length, and the alleged PE did not justify an additional taxable profit in India. On that basis, the addition was deleted and the PE issue was treated as tax-neutral for the dispute. en-us Tue, 08 Mar 2022 00:00:00 +0530 Mon, 21 Mar 2022 08:15:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=419798 Where the Indian associated enterprise was already remunerated at arm's length for the functions performed, assets employed and risks assumed, no further profit could be attributed to the foreign enterprise on account of a dependent agency permanent establishment. The transfer pricing analysis had accepted the international transactions at arm's length, and the alleged PE did not justify an additional taxable profit in India. On that basis, the addition was deleted and the PE issue was treated as tax-neutral for the dispute. Case-Laws Income Tax Tue, 08 Mar 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=419798