No further income attributable to a PE in India, if PE been remunerated at ALP

Mobileum Inc Vs DCIT (ITAT Mumbai)

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.

FULL TEXT OF THE ORDER OF ITAT MUMBAI

This appeal by the Assessee is directed against the order of learned CIT(A)-57 dated 30.03.2017 and pertains to Assessment Year 2012-13.

2. The grounds of appeal read as under :

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