Indian AE Transactions at Arm’s Length, HC Says No More Attribution

International Taxation -1 Vs Adobe Systems Software Ireland Ltd (Delhi High Court)

In a recent ruling Hon’ble Delhi HC dismissed appeals filed by revenue after considering the tribunal’s order who allowed assessee’s appeal after considering that since the transactions between the assessee and its Indian AE has been found to be at Arm’s Length in the transfer pricing adjustment, no further attribution can be made to the PE of the assessee as claimed.

Respondent/assessee is a Irish company. It accordingly claimed benefits of the India-Ireland DTAA. ADIR

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