https://www.taxtmi.com/caselaws?id=800017 Inadvertent omission to give effect to binding DRP directions, where apparent from the assessment record, may be rectified under Section 154 within the prescribed limitation and does not invalidate the final assessment order. Under the India-USA DTAA, an Indian subsidiary does not constitute a permanent establishment without supporting facts, so business profits are not attributable to India. Back-to-back expense reimbursements without mark-up are not fees for included services unless qualifying technical or consultancy services satisfy the Article 12(4)(b) make-available test. Corporate-guarantee commission cannot be estimated without examining the taxpayer's transfer-pricing benchmarking and relevant facts, requiring fresh determination. en-us Fri, 25 Sep 2026 00:00:00 +0530 Wed, 30 Sep 2026 08:41:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800017 Inadvertent omission to give effect to binding DRP directions, where apparent from the assessment record, may be rectified under Section 154 within the prescribed limitation and does not invalidate the final assessment order. Under the India-USA DTAA, an Indian subsidiary does not constitute a permanent establishment without supporting facts, so business profits are not attributable to India. Back-to-back expense reimbursements without mark-up are not fees for included services unless qualifying technical or consultancy services satisfy the Article 12(4)(b) make-available test. Corporate-guarantee commission cannot be estimated without examining the taxpayer's transfer-pricing benchmarking and relevant facts, requiring fresh determination. Case-Laws Income Tax Fri, 25 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800017