https://www.taxtmi.com/caselaws?id=303987 Profits attributable to an agency permanent establishment in India could not be taxed again once the Indian agent's commission was accepted as arm's length. The assessee had appointed its Indian subsidiary as sales agent on a cost-plus markup basis, and that compensation had already been accepted in the agent's assessment. Applying the attribution principle, only income properly referable to the permanent establishment could be brought to tax in India, so no separate or additional attribution was warranted in the non-resident assessee's hands. The ITAT Mumbai followed its earlier year decision on identical facts and confirmed that no further income was attributable beyond the arm's length commission. en-us Wed, 10 Apr 2019 00:00:00 +0530 Wed, 31 Aug 2022 05:44:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=303987 Profits attributable to an agency permanent establishment in India could not be taxed again once the Indian agent's commission was accepted as arm's length. The assessee had appointed its Indian subsidiary as sales agent on a cost-plus markup basis, and that compensation had already been accepted in the agent's assessment. Applying the attribution principle, only income properly referable to the permanent establishment could be brought to tax in India, so no separate or additional attribution was warranted in the non-resident assessee's hands. The ITAT Mumbai followed its earlier year decision on identical facts and confirmed that no further income was attributable beyond the arm's length commission. Case-Laws Income Tax Wed, 10 Apr 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=303987