https://www.taxtmi.com/caselaws?id=444476 Where an Indian associated enterprise has already been remunerated at arm's length on transfer pricing analysis, no further profit is ordinarily attributable to an alleged dependent agent permanent establishment on the same functions and risks, and the corresponding adjustment was deleted. Interest on income-tax refund payable to an Irish resident was held taxable at the 10% treaty rate under the India-Ireland DTAA, as the treaty prevailed over the Act. Claims for TDS credit and relief from additional tax on special income were remitted for verification and consequential relief in accordance with law. en-us Thu, 12 Oct 2023 00:00:00 +0530 Mon, 16 Oct 2023 15:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=444476 Where an Indian associated enterprise has already been remunerated at arm's length on transfer pricing analysis, no further profit is ordinarily attributable to an alleged dependent agent permanent establishment on the same functions and risks, and the corresponding adjustment was deleted. Interest on income-tax refund payable to an Irish resident was held taxable at the 10% treaty rate under the India-Ireland DTAA, as the treaty prevailed over the Act. Claims for TDS credit and relief from additional tax on special income were remitted for verification and consequential relief in accordance with law. Case-Laws Income Tax Thu, 12 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=444476