https://www.taxtmi.com/caselaws?id=793291 Profit attribution to an Indian Permanent Establishment must follow the actual functional role in each transaction and the supporting evidence. On the disputed merger and acquisition executions, the record showed material involvement of the UK office, including email communications and the location of counterparties, and the attribution pattern in other transactions supported shared allocation where a branch played a significant role; the proposed addition was therefore deleted. The MAT credit claim was treated as a computational matter requiring factual verification, so the issue was restored to the assessing authority for examination and grant in accordance with law. en-us Wed, 10 Jun 2026 00:00:00 +0530 Sat, 13 Jun 2026 14:41:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793291 Profit attribution to an Indian Permanent Establishment must follow the actual functional role in each transaction and the supporting evidence. On the disputed merger and acquisition executions, the record showed material involvement of the UK office, including email communications and the location of counterparties, and the attribution pattern in other transactions supported shared allocation where a branch played a significant role; the proposed addition was therefore deleted. The MAT credit claim was treated as a computational matter requiring factual verification, so the issue was restored to the assessing authority for examination and grant in accordance with law. Case-Laws Income Tax Wed, 10 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793291