https://www.taxtmi.com/caselaws?id=447199 Where an Indian subsidiary alleged to constitute a permanent establishment had already been remunerated at arm's length, no further attribution of business profits was warranted if the adjusted computation left no taxable income in the hands of the permanent establishment. The Tribunal accepted that the assessee had a fixed place permanent establishment through the subsidiary, but held that the commission and remuneration already paid to the Indian entity eliminated any additional taxable profit attribution. The High Court found no reason to interfere and held that no substantial question of law arose, leaving the Tribunal's view undisturbed. en-us Mon, 04 Dec 2023 00:00:00 +0530 Tue, 19 Dec 2023 17:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447199 Where an Indian subsidiary alleged to constitute a permanent establishment had already been remunerated at arm's length, no further attribution of business profits was warranted if the adjusted computation left no taxable income in the hands of the permanent establishment. The Tribunal accepted that the assessee had a fixed place permanent establishment through the subsidiary, but held that the commission and remuneration already paid to the Indian entity eliminated any additional taxable profit attribution. The High Court found no reason to interfere and held that no substantial question of law arose, leaving the Tribunal's view undisturbed. Case-Laws Income Tax Mon, 04 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447199