Exclusive Motors cannot be construed as a dependent agent PE of CCPL

ACIT Vs Exclusive Motors Pvt. Ltd (ITAT Delhi)

Undisputedly, the assessing officer has concluded that part of the remittances made by assessee to CCPL towards extended warranty services are in the nature of profit attributable to the PE in India, hence, assessee was required to deduct tax at source on such remittances. He also held that while entering into extended warranty contracts with Indian customers, the assessee acted as a dependent agent PE of CCPL.

Assessee is an exclusive dealer

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