https://www.taxtmi.com/caselaws?id=768239 Profit attribution to a permanent establishment must rest on a proper functions-assets-risks analysis and, where applicable, transfer pricing support. The text explains that the foreign enterprise's major deliverables were prepared in Italy, while the Indian project office performed limited on-site technical support. An Assessing Officer's flat 50% attribution of gross receipts, made without comparable analysis or referral for transfer pricing examination, was described as ad hoc and unsustainable. It also states that dealings between a head office and its Indian permanent establishment may be examined as an international transaction, but no further adjustment is justified where the assessee has already applied a functional analysis and benchmarked arm's length attribution. en-us Fri, 28 Mar 2025 00:00:00 +0530 Thu, 03 Apr 2025 11:15:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768239 Profit attribution to a permanent establishment must rest on a proper functions-assets-risks analysis and, where applicable, transfer pricing support. The text explains that the foreign enterprise's major deliverables were prepared in Italy, while the Indian project office performed limited on-site technical support. An Assessing Officer's flat 50% attribution of gross receipts, made without comparable analysis or referral for transfer pricing examination, was described as ad hoc and unsustainable. It also states that dealings between a head office and its Indian permanent establishment may be examined as an international transaction, but no further adjustment is justified where the assessee has already applied a functional analysis and benchmarked arm's length attribution. Case-Laws Income Tax Fri, 28 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768239