ADARSH KUMAR GOEL,J. - (1.) Leave granted.
(2.) We have heard learned counsel for the parties and perused the record.
(3.) In the judgment of this Court dated 24th October, 2017 in Assistant Director of Income Tax-I, New Delhi v. M/s. E-Funds IT Solution Inc., Civil Appeal No. 6082 of 2015 and connected matters, it has been held that once arm's length principle has been satisfied, there can be no further profit attributable to a person even if it has a permanent establishment in India.;