https://www.taxtmi.com/caselaws?id=303971 The Tribunal ruled in favor of the appellant, finding the addition of Rs. 5,15,05,000 to the returned income by the Assessing Officer untenable. It held that if the arm's length price had been applied and paid, no further income should be attributed to the Permanent Establishment (PE) of the foreign enterprise in India. The Tribunal's decision was based on the application of transfer pricing principles and the arm's length price principle for commission payments, supported by relevant legal precedents. en-us Fri, 08 Feb 2019 00:00:00 +0530 Tue, 30 Aug 2022 08:34:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=303971 The Tribunal ruled in favor of the appellant, finding the addition of Rs. 5,15,05,000 to the returned income by the Assessing Officer untenable. It held that if the arm's length price had been applied and paid, no further income should be attributed to the Permanent Establishment (PE) of the foreign enterprise in India. The Tribunal's decision was based on the application of transfer pricing principles and the arm's length price principle for commission payments, supported by relevant legal precedents. Case-Laws Income Tax Fri, 08 Feb 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=303971