If agent been paid at ALP than existence of DAPE is wholly tax-neutral

ADIT Vs Asia Today Limited (ITAT Mumbai) It has not been the case of the revenue authorities at any stage that the remuneration paid to the Indian agent is not an arm’s length remuneration for the services rendered by the agents concerned, yet a prayer is now made that the matter should be sent back to the assessment stage for detailed findings in this regard. In a written note filed by the learned Departmental Representative, it has been submitted that, ‘it is humbly submitted that in the case of DIT Vs Morgan Stanley (292 ITR 416 (SC) The Hon’ble Apex Court in para 32 of its or...