Assessee is a non-resident corporate entity incorporated in Ireland and a tax resident of Ireland. The assessee is engaged in licensing of software in India through distributors to the end users. The issue which arose for consideration was that if the transaction between the assessee and its AE in India has been found to be at arm’s length, whether further profit can be attributed to the dependent agent PE in India, if at all, such a PE exists in India. The ITAT observed that the TPO had proposed transfer pricing adjustment in relation to the international transactions between the assessee and its Indian AE, however, DRP has deleted such adjustment also no reference was made to the TPO, in the subsequent AY under consideration. This meant that the transaction between the assessee and its Indian AE was found to be at arm’s length. It was further noted that in appeals for earlier AYs it was held that when the transaction between the assessee and its Indian AE is found to be at arm’s length, therefore no further attribution of profit can be made to the dependent agent PE in India. It was held that the present appeal stands covered in favour of the assessee by the earlier decisions of the ITAT and accordingly the additions were deleted.(AY. 2018-19,2019-20)