Outsourcing solutions to Indian subsidiary doesn’t result in creation of PE

CIT (International Tax-1) Vs EXL Service.Com Inc (Delhi High Court) Delhi High Court held that outsourcing solutions including transaction processing services and Internet/voice-based customer care services for its clients to subsidiary in India doesn’t result in creation of Permanent Establishment [PE] in India under India-USA DTAA. Facts- The Assessee is a company incorporated under the laws of Delaware, USA. It develops and deploys business process outsourcing solutions including transaction processing services and Internet/voice-based customer care services for its clients. The Assessee...