https://www.taxtmi.com/caselaws?id=760062 Delhi HC dismissed the revenue's appeal regarding permanent establishment determination for a foreign entity. The AO had found that the Indian subsidiary was adequately compensated at arm's length for installation, commissioning, and after-sales services. Since no attribution issues arose, the Fixed Place PE question became irrelevant. For the Pepsico project, the AO determined that work was awarded to the Indian subsidiary with the foreign entity only making supplies. Applying DAPE principles from Progress Rail Locomotive Inc, the court found no substantial questions of law warranting interference with the lower tribunal's decision. en-us Thu, 22 Aug 2024 00:00:00 +0530 Mon, 14 Oct 2024 17:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=760062 Delhi HC dismissed the revenue's appeal regarding permanent establishment determination for a foreign entity. The AO had found that the Indian subsidiary was adequately compensated at arm's length for installation, commissioning, and after-sales services. Since no attribution issues arose, the Fixed Place PE question became irrelevant. For the Pepsico project, the AO determined that work was awarded to the Indian subsidiary with the foreign entity only making supplies. Applying DAPE principles from Progress Rail Locomotive Inc, the court found no substantial questions of law warranting interference with the lower tribunal's decision. Case-Laws Income Tax Thu, 22 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=760062