Indian Subsidiary Compensated at ALP Not a Dependent Agent PE: Delhi HC

CIT (International Taxation) Vs Krones Aktiengesellschaft (Delhi High Court)

In the case of CIT (International Taxation)-2 vs. Krones Aktiengesellschaft, the Delhi High Court dismissed the appeal challenging the Income Tax Appellate Tribunal’s (ITAT) decision that Krones’ Indian subsidiary, KIPL, does not constitute a Dependent Agent Permanent Establishment (DAPE). The Principal Commissioner of Income Tax argued that KIPL performed extensive functions beyond earning commission and was actively involved in machinery installation and after-sales service, warranting its cl

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