No further profit attribution to dependent agent PE in India as transaction with Indian AE is at arm’s length

Adobe Systems Software Ireland Ltd. Vs ACIT (ITAT Delhi) ITAT Delhi held that 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. Facts- The assessee is a non-resident corporate entity incorporated in Ireland and a tax resident of Ireland. As stated by AO, the assessee is a wholly owned subsidiary of Adobe System, USA and is engaged in licensing software in India through distributors to the end users. The software licensed by the assessee is the intellectual property of Ad...