https://www.taxtmi.com/caselaws?id=449592 Where an Indian agent is remunerated at arm's length for the functions performed, assets employed and risks assumed, no further profit is ordinarily attributable to the foreign enterprise merely because a dependent agent permanent establishment is alleged to exist. Applying binding coordinate bench rulings and jurisdictional High Court principle, the Tribunal deleted the addition made on profit attribution. On the TDS credit claim, the matter was remitted to the Assessing Officer for factual verification and grant of credit in accordance with law, with the ground allowed for statistical purposes. en-us Wed, 14 Jun 2023 00:00:00 +0530 Wed, 14 Feb 2024 11:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449592 Where an Indian agent is remunerated at arm's length for the functions performed, assets employed and risks assumed, no further profit is ordinarily attributable to the foreign enterprise merely because a dependent agent permanent establishment is alleged to exist. Applying binding coordinate bench rulings and jurisdictional High Court principle, the Tribunal deleted the addition made on profit attribution. On the TDS credit claim, the matter was remitted to the Assessing Officer for factual verification and grant of credit in accordance with law, with the ground allowed for statistical purposes. Case-Laws Income Tax Wed, 14 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449592