https://www.taxtmi.com/caselaws?id=765347 Where an Indian associated enterprise's transactions were already accepted at arm's length, the Delhi HC held that no further profit attribution to an alleged permanent establishment could be made on the basis of assumptions, isolated emails, or conjecture. The court found that the transfer pricing analysis had adequately captured the relevant functions and risks, so the Revenue could not enlarge the scope of the Indian entity's activities without material support. It also held that broad remarks about a "Double Irish" structure and tax avoidance did not alter the factual position or provide an independent basis for additions. The Revenue's challenge therefore failed and the appeals were dismissed. en-us Thu, 23 Jan 2025 00:00:00 +0530 Thu, 30 Jan 2025 08:24:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765347 Where an Indian associated enterprise's transactions were already accepted at arm's length, the Delhi HC held that no further profit attribution to an alleged permanent establishment could be made on the basis of assumptions, isolated emails, or conjecture. The court found that the transfer pricing analysis had adequately captured the relevant functions and risks, so the Revenue could not enlarge the scope of the Indian entity's activities without material support. It also held that broad remarks about a "Double Irish" structure and tax avoidance did not alter the factual position or provide an independent basis for additions. The Revenue's challenge therefore failed and the appeals were dismissed. Case-Laws Income Tax Thu, 23 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765347