https://www.taxtmi.com/highlights?id=102103 Arm's-length remuneration of an Indian associated enterprise treated as a dependent agent permanent establishment is discussed as precluding further profit attribution to the non-resident where no transfer-pricing adjustment is made. The notes describe this approach as applying on identical facts to challenges concerning business connection, permanent establishment and attribution of profits. They also address interest on an income-tax refund, stating that it is not effectively connected with the alleged Indian permanent establishment and should be taxed under the interest article of the India-Singapore treaty rather than under normal domestic provisions. en-us Mon, 27 Jul 2026 08:27:45 +0530 Mon, 27 Jul 2026 08:27:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=102103 Arm's-length remuneration of an Indian associated enterprise treated as a dependent agent permanent establishment is discussed as precluding further profit attribution to the non-resident where no transfer-pricing adjustment is made. The notes describe this approach as applying on identical facts to challenges concerning business connection, permanent establishment and attribution of profits. They also address interest on an income-tax refund, stating that it is not effectively connected with the alleged Indian permanent establishment and should be taxed under the interest article of the India-Singapore treaty rather than under normal domestic provisions. Highlights Income Tax Mon, 27 Jul 2026 08:27:45 +0530 https://www.taxtmi.com/highlights?id=102103