https://www.taxtmi.com/caselaws?id=757654 Where transactions between a foreign enterprise and its Indian associated enterprise are accepted at arm's length, no further profit attribution should be made to an alleged dependent agent or fixed place PE on the same functions and risks. The Tribunal relied on earlier coordinate bench rulings in the assessee's own case and noted that the PE allegation lacked cogent basis. On that settled position, arm's length remuneration to the Indian entity was treated as exhausting additional attribution on the same facts, and the PE-based addition was deleted. en-us Fri, 09 Feb 2024 00:00:00 +0530 Wed, 28 Aug 2024 10:40:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757654 Where transactions between a foreign enterprise and its Indian associated enterprise are accepted at arm's length, no further profit attribution should be made to an alleged dependent agent or fixed place PE on the same functions and risks. The Tribunal relied on earlier coordinate bench rulings in the assessee's own case and noted that the PE allegation lacked cogent basis. On that settled position, arm's length remuneration to the Indian entity was treated as exhausting additional attribution on the same facts, and the PE-based addition was deleted. Case-Laws Income Tax Fri, 09 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757654