https://www.taxtmi.com/caselaws?id=795519 Dependent Agent Permanent Establishment attribution does not arise where the Indian affiliate's relevant transactions have been accepted at arm's length and the identical issue was previously resolved in the foreign enterprise's favour, with no contrary higher-forum ruling identified. The addition of business income on that basis is deleted. Interest on an income-tax refund cannot be assessed without examining whether it was received during the relevant year, particularly where it was absent from the show-cause notice and introduced in the draft assessment order. That issue requires fresh factual consideration; unrecovered refund interest cannot be taxed as income for the year. en-us Thu, 16 Jul 2026 00:00:00 +0530 Thu, 23 Jul 2026 08:42:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795519 Dependent Agent Permanent Establishment attribution does not arise where the Indian affiliate's relevant transactions have been accepted at arm's length and the identical issue was previously resolved in the foreign enterprise's favour, with no contrary higher-forum ruling identified. The addition of business income on that basis is deleted. Interest on an income-tax refund cannot be assessed without examining whether it was received during the relevant year, particularly where it was absent from the show-cause notice and introduced in the draft assessment order. That issue requires fresh factual consideration; unrecovered refund interest cannot be taxed as income for the year. Case-Laws Income Tax Thu, 16 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795519