Further Profit Attribution not required if Indian AE is remunerated at ALP

UPS Asia Group Pte. Ltd. Vs ACIT (ITAT Mumbai)

ITAT held that when Indian Associated Enterprise (AE) is remunerated at arm’s length price (ALP) no further profit attribution is required and the issue of existence of Permanent Establishment becomes wholly tax neutral.

FULL TEXT OF THE ORDER OF ITAT MUMBAI

The captioned appeal has been filed by the assessee against the final assessment order dated 29.04.2021 passed under section 143(3) read with section 144C(13) of the Income Tax Act, 1961 (“the Act

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