CONCENTRIX CVG CUSTOMER MANAGEMENT GROUP INC. ,UNITED STATES OF AMERICA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(2)(1), INTERNATIONAL TAXATION, DELHI

ITA 1892/DEL/2025Status: DisposedITAT Delhi30 September 2025AY 2022-23Bench: SHRI VIKAS AWASTHY (Judicial Member), SHRI AVDHESH KUMAR MISHRA (Accountant Member)17 pages
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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 outsourced customer and marketing support services. The dispute involved whether the assessee had a Permanent Establishment (PE) in India and the attribution of profits. The case was a second round of appeals before the Tribunal after being set aside by the High Court.

What were the issues?

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

Which sections of the Income-tax Act were involved?

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 Deputy Commissioner Management Group Inc., (Earlier of Income Tax, known as ‘Convergys Customer Vs Circle - 1(2)(1), Management Group Inc.’) International Taxation, C/o PWC Pvt. Ltd., E-2 Tower, Civic Centre Sucheta Bhawan, Minto Road Gate No. 2, 1st Floor, New Delhi 11-A, Vishnu Digambar Marg, New Delhi PAN: AACCC8989M (Appellant) (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 Concentrix CVG Customer Income Tax, Management Group Inc., Circle - 1(2)(1), Vs. (Earlier known as ‘Convergys International Taxation, Customer Management Group E-2 Tower, Civic Centre Inc.’) C/o. PWC Pvt. Ltd., Minto Road Sucheta Bhawan, New Delhi Gate

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