https://www.taxtmi.com/caselaws?id=312625 Where cross-border software and hardware transactions with an Indian group entity had already been accepted at arm's length in transfer pricing proceedings, further attribution of profits to an alleged permanent establishment was not justified. The attribution was also flawed because hardware receipts were included even though the permanent establishment allegation was confined to software distribution activities, so the core addition was deleted. Interest under section 234B was treated as consequential to the assessment, and initiation of penalty proceedings under section 270A was considered premature at that stage. en-us Mon, 10 Apr 2023 00:00:00 +0530 Wed, 28 Feb 2024 17:45:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=312625 Where cross-border software and hardware transactions with an Indian group entity had already been accepted at arm's length in transfer pricing proceedings, further attribution of profits to an alleged permanent establishment was not justified. The attribution was also flawed because hardware receipts were included even though the permanent establishment allegation was confined to software distribution activities, so the core addition was deleted. Interest under section 234B was treated as consequential to the assessment, and initiation of penalty proceedings under section 270A was considered premature at that stage. Case-Laws Income Tax Mon, 10 Apr 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=312625