https://www.taxtmi.com/caselaws?id=31858 In a treaty-based attribution dispute involving a non-resident and its Indian dependent agent, the Bombay HC stated that taxation in India is confined to profits directly or indirectly attributable to the permanent establishment under Article 7, and that this attribution exercise is distinct from transfer pricing under Section 92. Where the Indian agent is remunerated at arm's length and the treaty conditions and CBDT circular are satisfied, no further profits remain to be attributed to the foreign enterprise. The analysis also notes that the circular applies where business is wholly channelled through the agent, contracts are concluded outside India, and sales are on a principal-to-principal basis. en-us Fri, 22 Aug 2008 00:00:00 +0530 Mon, 08 Sep 2025 12:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=31858 In a treaty-based attribution dispute involving a non-resident and its Indian dependent agent, the Bombay HC stated that taxation in India is confined to profits directly or indirectly attributable to the permanent establishment under Article 7, and that this attribution exercise is distinct from transfer pricing under Section 92. Where the Indian agent is remunerated at arm's length and the treaty conditions and CBDT circular are satisfied, no further profits remain to be attributed to the foreign enterprise. The analysis also notes that the circular applies where business is wholly channelled through the agent, contracts are concluded outside India, and sales are on a principal-to-principal basis. Case-Laws Income Tax Fri, 22 Aug 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=31858