https://www.taxtmi.com/highlights?id=93384 The ITAT allowed the taxpayer's appeal, concluding that the Indian affiliate is not a dependent agent PE under Article 5(4) of the India-UK DTAA. The tribunal found the Indian entity to be a separate legal person performing marketing and sales support under its own management and resources, remunerated at arm's length, and lacking authority to bind the nonresident, conclude contracts, maintain stock, or deliver products on the nonresident's behalf. Consequently, the AO's and DRP's attribution of offshore sales profits to a PE in India was annulled and the corresponding income-tax additions were deleted. en-us Thu, 16 Oct 2025 08:30:14 +0530 Thu, 16 Oct 2025 08:30:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=93384 The ITAT allowed the taxpayer's appeal, concluding that the Indian affiliate is not a dependent agent PE under Article 5(4) of the India-UK DTAA. The tribunal found the Indian entity to be a separate legal person performing marketing and sales support under its own management and resources, remunerated at arm's length, and lacking authority to bind the nonresident, conclude contracts, maintain stock, or deliver products on the nonresident's behalf. Consequently, the AO's and DRP's attribution of offshore sales profits to a PE in India was annulled and the corresponding income-tax additions were deleted. Highlights Income Tax Thu, 16 Oct 2025 08:30:14 +0530 https://www.taxtmi.com/highlights?id=93384