https://www.taxtmi.com/caselaws?id=792663 Where transactions between the foreign enterprise and Indian group entities were accepted at arm's length, no further profit attribution to the dependent agent permanent establishments in India was warranted, and the addition was deleted. The Tribunal applied the settled principle, already followed in earlier years, that arm's length transfer pricing treatment excludes separate attribution of additional profits to the PE. The assessee's claim for interest under section 244A was not decided on merits and was remitted for factual verification by the Assessing Officer, who was directed to examine it and decide according to law. en-us Fri, 29 May 2026 00:00:00 +0530 Mon, 01 Jun 2026 08:25:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792663 Where transactions between the foreign enterprise and Indian group entities were accepted at arm's length, no further profit attribution to the dependent agent permanent establishments in India was warranted, and the addition was deleted. The Tribunal applied the settled principle, already followed in earlier years, that arm's length transfer pricing treatment excludes separate attribution of additional profits to the PE. The assessee's claim for interest under section 244A was not decided on merits and was remitted for factual verification by the Assessing Officer, who was directed to examine it and decide according to law. Case-Laws Income Tax Fri, 29 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792663