No addition If ALP principle is satisfied qua relevant transaction

Celltick Technologies Ltd Vs DCIT (ITAT Mumbai) If the arms length principle is satisfied qua the relevant transaction between the assessee and its Indian subsidiary, no further profits can be attributed to the assessee in India even if it was to be held that the latter had a PE in India e find that the Indian subsidiary of the assessee viz. M/s Celltick Mobile Media (India) Pvt. Ltd. had for A.Y. 2015-16 to A.Y 2019-20 entered into an ‘APA’ with the CBDT. As is discernible from the ‘APA’, the functions of the subsidiary company inter alia included “marketing and sale...