https://www.taxtmi.com/caselaws?id=432267 Receipts from software supply and automated services are discussed in relation to alleged dependent agent and fixed place permanent establishment exposure in India, with the note stating that where the Indian associated enterprise's transactions have already been benchmarked at arm's length, no further profit attribution to the alleged permanent establishment is warranted unless the transfer pricing analysis is shown to be incomplete. The note also addresses tax deducted at source credit, stating that the claim requires factual verification before credit can be granted in accordance with law. en-us Fri, 21 Oct 2022 00:00:00 +0530 Mon, 02 Jan 2023 08:36:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=432267 Receipts from software supply and automated services are discussed in relation to alleged dependent agent and fixed place permanent establishment exposure in India, with the note stating that where the Indian associated enterprise's transactions have already been benchmarked at arm's length, no further profit attribution to the alleged permanent establishment is warranted unless the transfer pricing analysis is shown to be incomplete. The note also addresses tax deducted at source credit, stating that the claim requires factual verification before credit can be granted in accordance with law. Case-Laws Income Tax Fri, 21 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=432267