Delmas France v. Asstt. DIT (IT)
17 Taxmann.com 91Income Tax Appellate Tribunal2012#2365 most cited
What is Delmas France v. Asstt. DIT (IT) authority for?
The ITAT evaluates the profit neutrality theory for a Dependent Agent Permanent Establishment (DAPE), stating that unlike a service PE, a DAPE assumes entrepreneurship risk which must be considered for arm's length remuneration.
49
judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2018 to 2024.
Also referred to as
Delmas France v. Asstt. DIT · dependent agent PE · DAPE · agency PE · entrepreneurship risk · profit neutrality theory · arm's length principle · transfer pricing · Morgan Stanley
Also reported as
49 SOT 719
Sections most often in play
Issues it is cited on
Judgments citing Delmas France v. Asstt. DIT (IT)
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