PE case lawIndian Court rules no further profit attribution needed for Singapore company's Indian operationsOn 21 March 2024, the Delhi Bench of the Income Tax Appellate Tribunal (ITAT) ruled in favor of a Singapore company, holding that no further profits are attributable to its alleged permanent establishment (PE) in India, where its Indian associated enterprise (AE) had already been remunerated at arm's length.The case stemmed from Indian tax authorities' earlier determination that the Singapore company's Indian AE constituted a fixed-place PE and a dependent agent PE. Consequently, the authorities attributed profits to this alleged PE. The ITAT had initially ruled...