No Fixed Place, Service PE or DAPE: ITAT Delhi Holds No PE in India, Profit Attribution Quashed

Concentrix CVG Customer Management Group Inc. Vs DCIT (ITAT Delhi) Assessee, a US tax resident, provides customer & marketing support services to global clients, with its Indian subsidiary Convergys India Services Pvt. Ltd. (CIS) offering IT-enabled back-office/call centre services on a cost-plus basis. Revenue alleged that employees of the Assessee frequently visited CIS premises, exercising control & supervision, thereby creating Fixed Place PE, Service PE & Dependent Agent PE in India. AO also treated IPLC/link charges as royalty. Additions were made attributing large profits to...