Dismissing the appeal of the revenue the Court held that once arm’s length principle has been satisfied, there can be no further profit attributable to assessee, even if assessee has a Permanent Establishment. (A.Y. 2007-08)
CIT(IT) v. Honda Motors Co. Ltd. (2020) 274 Taxman 342 (Delhi)(HC) Editorial : SLP dismissed on the ground of delay , CIT(IT) v. Honda Motors Co. Ltd ( 2021 ) 278 Taxman 272 ( SC)
S. 92C : Transfer pricing-Arm’s length price-No addition can be made even if assessee has Permanent Establishment in India. [S. 9(1)(i)]