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Outsourcing solutions to Indian subsidiary doesn’t result in creation of PE
Case Law Details
- Case Name
- CIT (International Tax-1) Vs EXL Service.Com Inc (Delhi High Court)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2006-07
- Courts
- All High Courts, Delhi High Court
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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...
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