[ compiled answer ]
law as at 14 Aug 2026 · judicial
Does arm's-length remuneration extinguish PE profit attribution?
The compiled answer
Where the Indian associated enterprise is remunerated at arm's length taking account of all risk-taking functions, nothing further remains attributable to the PE — DIT v. Morgan Stanley & Co Inc, (2007) 292 ITR 416 (SC). Existence and exposure are separate questions: a PE may exist with nil further attribution. Caveat: India–US Article 7(1)(b)-(c) carries a limited force of attraction for same-or-similar business.
Pinpoint
DIT v. Morgan Stanley & Co Inc, (2007) 292 ITR 416 (SC)
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