Held that the Tribunal had held that when the transactions between the assessee and its Indian associated enterprise were found to be at arm’s length, no further attribution of profits could be made to the dependent agent permanent establishment in India.(AY. 2018-19, 2019-20)
Adobe Systems Software Ireland Ltd v. ACIT (IT ) (2023)106 ITR 475 / 150 taxmann.com 437 (Delhi)(Trib)
S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Non-Resident-Supply of software and automated services-Arm’s length-Attribution of profits-DTAA-India-Ireland . [ S.92C , art.5, 11 ]