https://www.taxtmi.com/highlights?id=104359 DRP directions bind the final assessment order, but a patent computation omission may be rectified within the statutory period where the directions were reproduced but not implemented. An Indian subsidiary does not create a permanent establishment merely on facts previously found insufficient to establish one, so no business-profit attribution follows on that basis. Third-party cost reimbursements received without mark-up are not fees for included services unless the services are technical or consultancy services and make available the requisite technical knowledge or know-how under the India-USA DTAA. Corporate guarantee commission must be benchmarked on the taxpayer's facts; a fixed formula without examining the taxpayer's benchmarking is inappropriate. en-us Wed, 30 Sep 2026 08:41:54 +0530 Wed, 30 Sep 2026 08:41:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=104359 DRP directions bind the final assessment order, but a patent computation omission may be rectified within the statutory period where the directions were reproduced but not implemented. An Indian subsidiary does not create a permanent establishment merely on facts previously found insufficient to establish one, so no business-profit attribution follows on that basis. Third-party cost reimbursements received without mark-up are not fees for included services unless the services are technical or consultancy services and make available the requisite technical knowledge or know-how under the India-USA DTAA. Corporate guarantee commission must be benchmarked on the taxpayer's facts; a fixed formula without examining the taxpayer's benchmarking is inappropriate. Highlights Income Tax Wed, 30 Sep 2026 08:41:54 +0530 https://www.taxtmi.com/highlights?id=104359