https://www.taxtmi.com/caselaws?id=306991 A dependent agency permanent establishment is treated as tax-neutral where the Indian agent has already been remunerated at arm's length for the functions performed, assets employed and risks assumed. On that basis, no further profits can be attributed to the foreign enterprise in India, and the addition described in the note is stated to be unsustainable. The note also indicates that attribution, gross profit basis and interest-related grounds do not survive independently once the core taxability fails. en-us Mon, 30 May 2022 00:00:00 +0530 Fri, 10 Mar 2023 22:05:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306991 A dependent agency permanent establishment is treated as tax-neutral where the Indian agent has already been remunerated at arm's length for the functions performed, assets employed and risks assumed. On that basis, no further profits can be attributed to the foreign enterprise in India, and the addition described in the note is stated to be unsustainable. The note also indicates that attribution, gross profit basis and interest-related grounds do not survive independently once the core taxability fails. Case-Laws Income Tax Mon, 30 May 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306991