No Further Profit Attribution Once Indian AE Is Remunerated at Arm’s Length: Mumbai ITAT

UPS Asia Group Pte. Ltd. Vs ACIT (ITAT Mumbai) Mumbai ITAT Reiterates: No Further Profit Attribution to Foreign Enterprise Once Indian AE Is Remunerated at Arm’s Length The Mumbai ITAT held that no further profits can be attributed to a foreign enterprise’s alleged Permanent Establishment (PE) or business connection in India where its Indian Associated Enterprise (AE)/Dependent Agent PE has already been remunerated at an arm’s length price. Following its own decisions in the assessee’s earlier years, the Tribunal observed that once the Indian AE has been compensated on ...