Section 9 of the Income Tax Act, 1961—Income - Income deemed to accrue or arise in India —Nothing is brought on record to show whether the services of the seconded employee has been utilized towards international transactions of the Indian entity or has been utilized in domestic market and even the services has been utilized by Associated Enterprises and remunerated at arm’s length price to ‘Teradata India’, will not make any impact, as in the instant case the income taxable in the hands of the PE is under consideration and nothing has been brought on record that Arm’s Length Price of the service transaction between PE of assessee and Indian Entity has been determined but what is relevant here is that income has to be taxed in the hands of the correct person and in the instant case income from rendering services by the PE has to be taxed in the hands of the PE and remunerating the Teradata India by other AEs at arm’s-length price is not relevant, thus, the argument of assessee that Teradata India was remunerated at arm’s length price under transfer pricing principles was rejected - TERADATA OPERATIONS INC. V/s DEPUTY CIT - [2020] 82 ITR (TRIB) 338 (ITAT-DELHI)