How many judgments cite DIT v. E-Funds IT Solution?

61 judgments on BharatTax cite DIT v. E-Funds IT Solution (364 ITR 256), spanning 2015 to 2025.

Which sections of the Income Tax Act does DIT v. E-Funds IT Solution come up under?

It is most often cited in judgments turning on Section 143(3), Section 144C(13), Section 234A, Section 234B, Section 270A, Section 5.

DIT v. E-Funds IT Solution

364 ITR 256High Court2014#1883 most cited

What is DIT v. E-Funds IT Solution authority for?

A subsidiary is an independent legal entity, and the mere relationship of holding-subsidiary or control by itself does not result in a Permanent Establishment (PE) for the foreign company in India, whether it be a fixed place PE or a dependent agent PE, even when the subsidiary provides outsourced services.

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2015 to 2025.

Also referred to as

DIT v. E-Funds IT Solution · E-Funds IT Solution Permanent Establishment · Fixed Place PE · Dependent Agent PE · India-US DTAA · Indian subsidiary PE · independent legal entity · outsourcing services · Article 5 DTAA · section 9(1) Income Tax Act · 364 ITR 256

Also reported as

42 Taxmann.com 50226 Taxmann 44

Sections most often in play

Section 143(3)Section 144C(13)Section 234A Section 234B Section 270A Section 5 Section 12 Section 9(1)(vi)

Issues it is cited on

dependent agent pe profit split method agency pe fixed place pe service pe section 206c(6)make available clause section 206c(7)penalty under section 270a section 9(1)(vi)permanent establishment section 260

Judgments citing DIT v. E-Funds IT Solution

Commissioner of Income Tax (TDS) vs. M/s Country Club Inda Limited

ITTA/667/2014HC Telangana29 Jan 2015