Fresh Adjudication Ordered on TPO Adjustment in Subsidiary Transaction

QlikTech International ABC/o QlikTech India Pvt. Ltd. Vs DCIT (ITAT Bangalore) The Bangalore Income Tax Appellate Tribunal (ITAT) has set aside the Assessing Officer’s (AO) classification of QlikTech India Private Limited as a dependent agent permanent establishment (PE) of QlikTech International. The decision, rendered on December 16, 2024, stems from an appeal filed by QlikTech International against an order by the Deputy Commissioner of Income Tax (DCIT) for the assessment year 2021-22. The core dispute revolved around the taxability of income earned by the foreign company from its In...