No Profit can be Attributed if Commission Paid  to Ricardo India is Adjusted Against Profit Attributed to PE: Delhi HC [Read Order]

In a significant development, the Delhi High Court has delivered a crucial judgment in favor of a United Kingdom-based company, resolving a contentious tax dispute for the Assessment Year 2016-17.
Commission Paid - Profit - Ricardo India - Permanent Establishment - delhi high court - delhi hc - TAXSCAN

In a landmark decision, the Delhi High Court has ruled that no additional profit can be attributed to the Permanent Establishment (PE) of a UK-based company operating in India when adjusting the commission paid to its domestic subsidiary, Ricardo India Pvt. Ltd. The appellant, the revenue department, sought to challenge the order dated 17.02.2021 passed…

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