Mumbai ITAT Rejects Excess PE Attribution: Revenue Sharing with UK Office Upheld in Cross-Border M&A Deals

BDA Partners Limited Vs DCIT (ITAT Mumbai) Mumbai ITAT Rejects Excess PE Attribution: Revenue Sharing with UK Office Upheld in Cross-Border M&A Deals The Mumbai ITAT deleted an addition of ₹6.49 crore made on account of profit attributed to the Indian Permanent Establishment (PE) of a Hong Kong-based M&A advisory firm, holding that the Revenue had wrongly ignored the significant role played by the UK office in executing two cross-border merger and acquisition transactions. The assessee, engaged in global M&A advisory services, followed a revenue allocation model under which deal ...