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No further additions if amount remunerated by foreign Co. to Indian subsidiary was as per APA

October 4, 2019[2019] 109 334 (Mumbai)

INTERNATIONAL TAXATION: Where assessee-Israeli company provided software solutions to its Indian subsidiary for onward distribution to third party customers in India and amount remunerated by assessee to said subsidiary was found to be satisfying arm's length principle as per Advance Pricing Agreement (APA), no further profits could be attributed to Indian subsidiary even if it had PE in India

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