https://www.taxtmi.com/highlights?id=74922 Taxability of software sale by the US entity to Indian entities - Indian subsidiary is held as DAPE [Dependent Agent Permanent Establishment] of the assessee in India - when DAPE is remunerated at arm’s length - The Tribunal, following its previous rulings, found the assessment to misinterpret the distribution agreement and BAPA, holding that if the DAPE is remunerated at arm's length, no further addition can be made. en-us Thu, 15 Feb 2024 07:31:03 +0530 Thu, 15 Feb 2024 07:31:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=74922 Taxability of software sale by the US entity to Indian entities - Indian subsidiary is held as DAPE [Dependent Agent Permanent Establishment] of the assessee in India - when DAPE is remunerated at arm’s length - The Tribunal, following its previous rulings, found the assessment to misinterpret the distribution agreement and BAPA, holding that if the DAPE is remunerated at arm's length, no further addition can be made. Highlights Income Tax Thu, 15 Feb 2024 07:31:03 +0530 https://www.taxtmi.com/highlights?id=74922