Question of Ascertaining Existence of PE Academic when Arm Length Remuneration issue settled by TPO: Delhi HC quashes Re-Assessment Proceedings [Read Order]
The Delhi High Court, while quashing the reassessment proceedings initiated by the income tax department against the Caterpillar Group, held that once the issue of arm's length remuneration was settled by the Transfer Pricing Officer, the question of ascertaining the existence of a permanent establishment was academic.
The Delhi High Court quashed re-assessment proceedings and held that the question of ascertaining existence of PE academic when arm length remuneration issue settled by the Transfer Pricing Officer (TPO). As per the petitioner, it has no income which can be said to accrue or arise in India under the provisions of the Act and…
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