https://www.taxtmi.com/caselaws?id=466032 Issue concerns whether a foreign enterprise has a permanent establishment in India by virtue of its subsidiary and whether related transactions require adjustment. ITAT found no permanent establishment in India via the subsidiary and treated intercompany dealings under arm's length price analysis, resulting in no PE attribution. The matter was held to be governed by existing Supreme Court precedents addressing PE and attribution, and prior Delhi High Court authority, with the consequence that no substantial question of law remained for determination. en-us Wed, 13 Nov 2024 00:00:00 +0530 Tue, 20 Jan 2026 21:18:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466032 Issue concerns whether a foreign enterprise has a permanent establishment in India by virtue of its subsidiary and whether related transactions require adjustment. ITAT found no permanent establishment in India via the subsidiary and treated intercompany dealings under arm's length price analysis, resulting in no PE attribution. The matter was held to be governed by existing Supreme Court precedents addressing PE and attribution, and prior Delhi High Court authority, with the consequence that no substantial question of law remained for determination. Case-Laws Income Tax Wed, 13 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466032