Indian Subsidiary Not a Dependent Agency PE if Transactions Are Subject to TPO Adjustment

Qlik Tech International AB Vs DCIT (ITAT Bangalore)

In the case of Qlik Tech International AB vs DCIT, the Income Tax Appellate Tribunal (ITAT) Bangalore reviewed the assessment order concerning the classification of Qlik Tech’s Indian subsidiary as a dependent agent permanent establishment (PE). The AO had deemed the Indian subsidiary, Qliktech India Pvt. Ltd., a dependent agent PE based on its role in identifying customers, negotiating terms, and concluding contracts for software sales. Consequently, the AO attributed taxable income to the foreign entity and impose

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