Indian-Subsidiary Which Is Compensated At Arm's Length Can't Be Construed As Dependent Agent PE: Delhi High Court

The Delhi High Court ruled that an Indian subsidiary compensated at arm's length cannot be deemed a dependent agent Permanent Establishment (PE). This decision clarifies that if a subsidiary's transactions are conducted at arm's length, it does not automatically create a dependent agent PE under international tax rules, thus protecting the subsidiary from additional tax liabilities.