https://www.taxtmi.com/caselaws?id=432267 Arm's-length remuneration of an Indian associated enterprise can eliminate further profit attribution to an alleged permanent establishment where the transfer pricing analysis adequately captures the relevant functions and risks. Receipts from software supply and automated services were therefore not taxable in India through additional attribution to a dependent-agent or fixed-place permanent establishment, and the additions were deleted. Tax deducted at source credit required factual verification; the Assessing Officer was directed to verify the claim and grant credit 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 Arm's-length remuneration of an Indian associated enterprise can eliminate further profit attribution to an alleged permanent establishment where the transfer pricing analysis adequately captures the relevant functions and risks. Receipts from software supply and automated services were therefore not taxable in India through additional attribution to a dependent-agent or fixed-place permanent establishment, and the additions were deleted. Tax deducted at source credit required factual verification; the Assessing Officer was directed to verify the claim and grant credit in accordance with law. Case-Laws Income Tax Fri, 21 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=432267