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2018 (4) TMI 1515 - ITAT MUMBAIIncome accrued in India - fixed place PE in India - Income taxable in India - place of business in India - assessee has paid arm’s length remuneration/commission to its agent in India - Held that:- since transactions between the assessee and its AE have been found at arm’s length prices no further income chargeable to tax in India can be said to be attributable for the PE of the assessee. See Assistant Director of Income Tax-I, New Delhi Versus M/s E-Funds IT Solution Inc. [2017 (10) TMI 1011 - SUPREME COURT OF INDIA] - Hence this ground is decided in favour of the assessee.
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