https://www.taxtmi.com/highlights?id=99242 Where a dependent agent permanent establishment in India has already been remunerated at arm's length, no further profits are attributable to that permanent establishment. Applying Morgan Stanley and Honda Motors, the ITAT held that the AO's ad hoc attribution of revenue and estimation of profit under Rule 10 was unjustified because the transfer pricing study had been furnished and the arm's length nature of the transactions was neither adversely examined nor doubted. The addition for further profit attribution was deleted, and the remaining grounds were treated as academic. en-us Tue, 28 Apr 2026 07:29:33 +0530 Tue, 28 Apr 2026 07:29:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=99242 Where a dependent agent permanent establishment in India has already been remunerated at arm's length, no further profits are attributable to that permanent establishment. Applying Morgan Stanley and Honda Motors, the ITAT held that the AO's ad hoc attribution of revenue and estimation of profit under Rule 10 was unjustified because the transfer pricing study had been furnished and the arm's length nature of the transactions was neither adversely examined nor doubted. The addition for further profit attribution was deleted, and the remaining grounds were treated as academic. Highlights Income Tax Tue, 28 Apr 2026 07:29:33 +0530 https://www.taxtmi.com/highlights?id=99242