Permanent Establishment in India: No Extra Profit Attribution Needed if FAR Compensated at Arm's Length Price.

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....Business connection in India - Existence of Fixed PE In India and service PE In India - s even if assumed that there is a PE in India of the assessee no profit can be attributed to it as FAR (Functions performed, Assets deployed and Risk Assumed) such PE has already been compensated at arm's length price and therefore nothing more should be attributed to it. - AT....