Permanent establishment – Others : Where India subsidiary did not perform any additional functions that would lead to creation of a PE in India, remuneration for same would ideally be NIL and ,thus, amount of profits already offered to taxes by Indian entity should be considered to be at arm’s length and no further attribution is required – AB Sciex (P.) Ltd. v. Assistant Commissioner of Income-tax, Circle, IT 1(1)(1) – [2024] 160 taxmann.com 593 (Delhi – Trib.)