https://www.taxtmi.com/caselaws?id=469858 Where a Singapore freight forwarding and logistics enterprise used an Indian associate under a regional transport services arrangement, the note states that the associate may constitute a business connection and dependent agent PE under section 9(1)(i) and Article 5, but no further profits are attributable to India if the Indian associate is already remunerated at arm's length for the functions performed, assets employed and risks assumed. On that basis, any additional profit attribution to the foreign enterprise is unsustainable, and the arm's length remuneration is treated as exhausting the taxable attribution in India. en-us Tue, 24 Jan 2023 00:00:00 +0530 Tue, 07 Jul 2026 13:00:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469858 Where a Singapore freight forwarding and logistics enterprise used an Indian associate under a regional transport services arrangement, the note states that the associate may constitute a business connection and dependent agent PE under section 9(1)(i) and Article 5, but no further profits are attributable to India if the Indian associate is already remunerated at arm's length for the functions performed, assets employed and risks assumed. On that basis, any additional profit attribution to the foreign enterprise is unsustainable, and the arm's length remuneration is treated as exhausting the taxable attribution in India. Case-Laws Income Tax Tue, 24 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469858