https://www.taxtmi.com/caselaws?id=470309 The Tribunal's earlier direction for fresh adjudication on dependent-agent permanent establishment was modified to limit the scope of set-aside proceedings. The software transaction between the foreign enterprise and its Indian subsidiary had already been accepted as a sale-and-purchase transaction and subjected to transfer-pricing determination in the subsidiary's case. As the Revenue did not contest the request, the dependent-agent permanent-establishment issue is to be examined only within the specified verification framework. en-us Thu, 22 May 2025 00:00:00 +0530 Wed, 22 Jul 2026 20:59:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470309 The Tribunal's earlier direction for fresh adjudication on dependent-agent permanent establishment was modified to limit the scope of set-aside proceedings. The software transaction between the foreign enterprise and its Indian subsidiary had already been accepted as a sale-and-purchase transaction and subjected to transfer-pricing determination in the subsidiary's case. As the Revenue did not contest the request, the dependent-agent permanent-establishment issue is to be examined only within the specified verification framework. Case-Laws Income Tax Thu, 22 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470309