https://www.taxtmi.com/caselaws?id=790618 Where the Indian associated enterprise or dependent agent is remunerated at arm's length, no further profit can be attributed to the foreign enterprise merely because a permanent establishment exists in India. The Tribunal noted that the transfer pricing material supporting arm's length remuneration was not doubted by the assessing authority, and held that ad hoc attribution of revenue and profits under Rule 10 was unsustainable on those facts. The addition was therefore deleted. en-us Wed, 07 Jan 2026 00:00:00 +0530 Tue, 28 Apr 2026 07:29:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790618 Where the Indian associated enterprise or dependent agent is remunerated at arm's length, no further profit can be attributed to the foreign enterprise merely because a permanent establishment exists in India. The Tribunal noted that the transfer pricing material supporting arm's length remuneration was not doubted by the assessing authority, and held that ad hoc attribution of revenue and profits under Rule 10 was unsustainable on those facts. The addition was therefore deleted. Case-Laws Income Tax Wed, 07 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790618