https://www.taxtmi.com/caselaws?id=428593 The Tribunal allowed the appeal, setting aside the Commissioner of Income Tax's revision order. It held that the arm's length remuneration paid to the dependent agent exhausted the tax liability of the Dependent Agent Permanent Establishment (DAPE), making further profit attribution unnecessary. Errors in the Function Asset Risk (FAR) analysis were deemed academic and did not affect the overall tax liability. The Tribunal emphasized that the non-levy of taxes on hypothetical profits of the DAPE, beyond the dependent agent's taxability, was not prejudicial to revenue. en-us Tue, 30 Aug 2022 00:00:00 +0530 Wed, 05 Oct 2022 08:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=428593 The Tribunal allowed the appeal, setting aside the Commissioner of Income Tax's revision order. It held that the arm's length remuneration paid to the dependent agent exhausted the tax liability of the Dependent Agent Permanent Establishment (DAPE), making further profit attribution unnecessary. Errors in the Function Asset Risk (FAR) analysis were deemed academic and did not affect the overall tax liability. The Tribunal emphasized that the non-levy of taxes on hypothetical profits of the DAPE, beyond the dependent agent's taxability, was not prejudicial to revenue. Case-Laws Income Tax Tue, 30 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=428593