https://www.taxtmi.com/caselaws?id=443393 Where international transactions between a foreign enterprise and its Indian associated enterprise were accepted as arm's length, no further profit attribution could be made to an alleged dependent agent permanent establishment in India. The Tribunal held that once transfer pricing benchmarking adequately captured functions and risks, nothing remained to be separately attributed to the alleged PE. On that basis, the additions were deleted in favour of the assessee. The existence of the alleged permanent establishment was left open, but the taxability additions relating to software supply and automated services could not survive after acceptance of arm's length pricing. en-us Tue, 28 Feb 2023 00:00:00 +0530 Thu, 21 Sep 2023 10:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=443393 Where international transactions between a foreign enterprise and its Indian associated enterprise were accepted as arm's length, no further profit attribution could be made to an alleged dependent agent permanent establishment in India. The Tribunal held that once transfer pricing benchmarking adequately captured functions and risks, nothing remained to be separately attributed to the alleged PE. On that basis, the additions were deleted in favour of the assessee. The existence of the alleged permanent establishment was left open, but the taxability additions relating to software supply and automated services could not survive after acceptance of arm's length pricing. Case-Laws Income Tax Tue, 28 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=443393