https://www.taxtmi.com/caselaws?id=306991 Arm's-length remuneration of an Indian agent for its functions, assets and risks leaves no further profits attributable to an alleged dependent agency permanent establishment of the foreign enterprise. Where that remuneration is accepted as arm's length, the dependent agency permanent establishment is tax-neutral and an addition based on software-product receipts cannot be sustained. Questions concerning profit attribution, gross-profit basis and interest do not independently survive once the underlying taxability fails. The addition was directed to be deleted and the appeal succeeded for the assessee. 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 Arm's-length remuneration of an Indian agent for its functions, assets and risks leaves no further profits attributable to an alleged dependent agency permanent establishment of the foreign enterprise. Where that remuneration is accepted as arm's length, the dependent agency permanent establishment is tax-neutral and an addition based on software-product receipts cannot be sustained. Questions concerning profit attribution, gross-profit basis and interest do not independently survive once the underlying taxability fails. The addition was directed to be deleted and the appeal succeeded for the assessee. Case-Laws Income Tax Mon, 30 May 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306991