https://www.taxtmi.com/caselaws?id=427045 Where an Indian agent's commission for sales support services has been accepted at arm's length, no further profit attribution to the foreign enterprise's Indian permanent establishment is warranted absent any change in facts or law. The tribunal noted that the same arrangement had already been accepted in the agent's assessment and that the issue had been decided in the assessee's favour in earlier years on the principle that arm's-length remuneration exhausts the taxable attribution in India. Following that recurring view, the addition for further attribution was deleted. en-us Mon, 01 Aug 2022 00:00:00 +0530 Wed, 31 Aug 2022 07:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=427045 Where an Indian agent's commission for sales support services has been accepted at arm's length, no further profit attribution to the foreign enterprise's Indian permanent establishment is warranted absent any change in facts or law. The tribunal noted that the same arrangement had already been accepted in the agent's assessment and that the issue had been decided in the assessee's favour in earlier years on the principle that arm's-length remuneration exhausts the taxable attribution in India. Following that recurring view, the addition for further attribution was deleted. Case-Laws Income Tax Mon, 01 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=427045