https://www.taxtmi.com/caselaws?id=469858 Arm's length remuneration to an Indian associate for functions performed, assets employed and risks assumed exhausts profit attribution to India for a Singapore freight-forwarding enterprise. Even where the associate creates a business connection under the Income-tax Act and a dependent agent permanent establishment under the tax treaty, no further profits remain taxable if the associate has received arm's length compensation. Applying earlier decisions and jurisdictional precedent, the Tribunal deleted the additional profit attribution in one appeal; the connected appeal on identical facts was dismissed under the same reasoning. 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 Arm's length remuneration to an Indian associate for functions performed, assets employed and risks assumed exhausts profit attribution to India for a Singapore freight-forwarding enterprise. Even where the associate creates a business connection under the Income-tax Act and a dependent agent permanent establishment under the tax treaty, no further profits remain taxable if the associate has received arm's length compensation. Applying earlier decisions and jurisdictional precedent, the Tribunal deleted the additional profit attribution in one appeal; the connected appeal on identical facts was dismissed under the same reasoning. Case-Laws Income Tax Tue, 24 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469858