https://www.taxtmi.com/caselaws?id=306235 Where transactions with an associated enterprise are already benchmarked at arm's length, no further profit attribution in India is warranted merely on the basis of an alleged permanent establishment. The transfer pricing study was treated as capturing the functions and risks assumed by the assessee, so the same income could not be subjected to additional attribution under the PE framework. The principle applied is that an arm's length remuneration for the relevant transactions exhausts the profit attribution exercise for those transactions, leaving no separate basis for further Indian taxation on the same stream of income. en-us Fri, 12 Jan 2018 00:00:00 +0530 Wed, 18 Jan 2023 08:32:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306235 Where transactions with an associated enterprise are already benchmarked at arm's length, no further profit attribution in India is warranted merely on the basis of an alleged permanent establishment. The transfer pricing study was treated as capturing the functions and risks assumed by the assessee, so the same income could not be subjected to additional attribution under the PE framework. The principle applied is that an arm's length remuneration for the relevant transactions exhausts the profit attribution exercise for those transactions, leaving no separate basis for further Indian taxation on the same stream of income. Case-Laws Income Tax Fri, 12 Jan 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306235