DCIT, CIRCLE-1(2)(1) INT. TAXATION, NEW DELHI vs. CONCENTRIX CVG CUSTOMER MANAGEMENT GROUP INC., USA

ITA 723/DEL/2023Status: DisposedITAT Delhi30 September 2025AY 2018-1923 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the assessee did not have a fixed place PE, dependent agent PE, or service PE in India. It also ruled that link charges/IPLC charges did not constitute royalty under the India-US DTAA.

What were the facts?

The assessee, a US-based company, provided customer management services through its Indian subsidiary. The core dispute revolved around whether the assessee had a Permanent Establishment (PE) in India and the subsequent attribution of profits. This was a second round of appeals after the Delhi High Court set aside previous tribunal orders.

What were the issues?

The key issues were the existence of a Permanent Establishment (PE) in India, the attribution of profits to such PE, and the taxability of link charges as royalty under the India-US Double Taxation Avoidance Agreement.

Which sections of the Income-tax Act were involved?

Section 5,Section 9(1)(vi),Section 234A,Section 234B,Section 270A

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Cases cited in this judgment(4)Show list

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Heard together (11 matters)

ITA No.7727/Del/2017
ITA No.7924/Del/2018
ITA No.1086/Del/2022
ITA No.667/Del/2023
ITA No.668/Del/2023
ITA No.3512/Del/2023
ITA No.1892/Del/2025
ITA No.130/Del/2018
ITA No.1281/Del/2022
ITA No.723/Del/2023
ITA No.724/Del/2023

Read from the judgment's own cause title. This page is filed under one of them.

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘D': NEW DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI AVDHESH KUMAR MISHRA, ACCOUNTANT MEMBER ITA No.7727/Del/2017, A.Y. 2013-14 ITA No.7924/Del/2018, A.Y. 2014-15 ITA No.1086/Del/2022, A.Y. 2017-18 ITA No.667/Del/2023, A.Y. 2018-19 ITA No.668/Del/2023, A.Y. 2019-20 ITA No.3512/Del/2023, A.Y. 2021-22 ITA No.1892/Del/2025, A.Y. 2022-23

Concentrix CVG Customer Management Group Inc., (Earlier known as ‘Convergys Customer Management Group Inc.') C/o PWC Pvt. Ltd., Sucheta Bhawan, Gate No. 2, 1st Floor, 11-A, Vishnu Digambar Marg, New Delhi PAN: AACCC8989M (Appellant) Deputy Commissioner of Income Tax, Vs Circle - 1(2)(1), International Taxation, E-2 Tower, Civic Centre Minto Road New Delhi (Respondent) ITA No.130/Del/2018, A.Y. 2013-14 ITA No.1281/Del/2022, A.Y. 2017-18 ITA No.723/Del/2023, A.Y. 2018-19 ITA No.724/Del/2023, A.Y. 2019-20

Deputy Commissioner of Income Tax, Circle - 1(2)(1), International Taxation, E-2 Tower, Civic Centre Minto Road New Delhi Concentrix CVG Customer Management Group Inc., Vs. (Earlier known as ‘Convergys Customer Management Group Inc.') C/o. PWC Pvt. Ltd., Sucheta Bhawan, Gate No. 2, 1st Floo

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