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2023 (9) TMI 1015 - ITAT DELHIIncome deemed to accrue or arise in India - profit attributed to fixed place PE - HELD THAT:- As decided in assessee own case [2022 (7) TMI 1365 - ITAT DELHI] when the transaction between the assessee and its Indian AE is found to be at arm’s length, no further attribution of profit can be made to the dependent agent PE in India . Also see HONDA MOTOR CO. LTD, JAPAN, [2018 (5) TMI 265 - SUPREME COURT] - Decided in favour of assessee. -
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