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“associated enterprise”

Transfer PricingSection 92ASection 92A2,562 judgments

The decision most relied on for associated enterprise is CIT v. EKL Appliances Ltd. (345 ITR 241), cited in 422 judgments on BharatTax.

Leading authorities on associated enterprise

CIT v. EKL Appliances Ltd.
345 ITR 241 · 2012 · High Court
422
citing judgments

Transfer pricing adjustments for outstanding receivables are permissible only if the Tax Officer establishes, through analysis over a period, a pattern indicating an international transaction intended to benefit an associated enterprise. The Tax Officer cannot question purely business decisions like royalty payments or exceed jurisdiction by applying cost-benefit analysis to determine the arm's length price of services.

Sassoon J. David & Co. Pvt. Ltd. v. CIT
118 ITR 261 · 1979 · Supreme Court
323
citing judgments

An expense incurred by an assessee for its own business, such as advertising, marketing, and promotional (AMP) expenses, cannot be disallowed merely because it incidentally or indirectly benefits the assessee's sister concerns or associated enterprises.

CIT v. Everest Kento Cylinders Ltd.
378 ITR 57 · 2015 · High Court
304
citing judgments

Corporate guarantee fees are subject to transfer pricing rules, and adjustments may be needed to account for differences between corporate guarantees and more liquid bank guarantees when determining arm's length price.

CIT v. Cotton Naturals (I) (P.) Ltd.
55 Taxmann.com 523 · 2015 · High Court
273
citing judgments

The interest rate for benchmarking foreign currency loans advanced to Associated Enterprises should be the market-determined rate applicable to the currency of the loan, such as LIBOR for US Dollar loans, rather than a domestic lending rate like the Indian PLR.

CIT v. Agnity India Technologies (P.) Ltd.
36 Taxmann.com 289 · 2013 · High Court
171
citing judgments

The Delhi High Court holds that Infosys Ltd. is not comparable to a captive software development service provider for transfer pricing analysis, given its huge turnover, high profit margins, ownership of intangible intellectual property rights, branded products, and differing risk profile.

DIT v. Morgan Stanley Co. Inc.
399 ITR 34 · 2017 · Supreme Court
162
citing judgments

Once a transfer pricing analysis has been undertaken for an Indian associated enterprise, no further profits are attributable to it as a Permanent Establishment, thereby extinguishing the need for additional profit attribution.

PCIT v. Redington (India) Ltd.
430 ITR 298 · 2021 · High Court
132
citing judgments

A corporate guarantee issued to Associated Enterprises (AEs) is an international transaction under Section 92B, requiring adjustments for guarantee commission due to inherent risk. The reasonable arm's length rate for benchmarking such corporate guarantees can be determined using internal or external comparable uncontrolled prices.

Sony India (P) Ltd. v. DCIT
114 ITD 448 · 2008 · ITAT
131
citing judgments

For transfer pricing purposes, functionally dissimilar entities that have significant business differences must be excluded from the list of comparables for benchmarking analysis. It also provides guidance on the non-allocation of advertisement, marketing, and promotion (AMP) expenses to other entities when incurred solely for the assessee's business.

Judgments citing associated enterprise

ACIT-3(1)(1), Mumbai, Ayakar Bhawan vs. Samsonite South Asia Pvt Ltd, Andheri

In the result, appeal of the Revenue is dismissed

ITA 4278/MUM/2025[2010-11]Status: DisposedITAT Mumbai30 Sept 2025AY 2010-11

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawalassessment Year: 2010-11 Assistant Commissioner Of Samsonite South Asia Pvt. Ltd. Income Tax 3(1)(1) 402/Ackruti Star, Midc, 607, Ayakar Bhawan, M.K. Andheri East, Vs. Road, Mumbai – 400093 Mumbai - 400020 (Pan: Aaacs8598L) (Appellant) (Respondent) Present For: Assessee : Jitendra Singh, Advocate Revenue : Shri Surendra Mohan, Sr. Dr Date Of Hearing : 12.08.2025 Date Of Pronouncement : 30.09.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Revenue Is Against The Order Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi Vide Order No. Itba/Nfac/S/250/2025-26/1075686655(1), Dated 21.04.2025, Passed Against The Order By Additional Commissioner Of Income Tax 8(3), Mumbai U/S.143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 30.03.2014, For Assessment Year 2010- 11. 2. Grounds Taken By The Revenue Are Reproduced As Under: (1) Whether On The Facts & In The Circumstances Of The Case & In Law, The Ld. Cit(A) Is Correct In Allowing The Entire Amount Of Rs.7,32,38,757/- Incurred By The Assessee For Building Of ‘Samsonite’ Brand Without Appreciating The Fact That These Expenses Were Incurred Towards Creating Intangible Rights In Its Favour Which Are Capable Of Giving Enduring Benefits To The Assessee Company & Hence Are Assignable Over A Number Of Year?

For Appellant: Jitendra Singh, AdvocateFor Respondent: Shri Surendra Mohan, Sr. DR
Section 143(3)

officer has not at all made any case that assessee's expenditure are in the nature of AMP expenditure aimed at benefiting the foreign associated enterprise. Learned counsel submitted that the brand belongs the AE and not to the assessee and hence there cannot be any reason for the assessing ... doesn't belong to the assessee and it is not the case of the revenue that assessee has incurred expenditure aimed at benefiting the associated enterprise this addition is clearly not sustainable. When the brand doesn't belong to the assessee there is no question of incurring expenditure over building

Assistant Commissioner of Income Tax, Central Circle-19, Delhi, New Delhi vs. M/S Jkm Infra Projects Ltd., Noida, Uttar Pradesh

In the result, the appeal of the revenue is dismissed and Cross

ITA 3031/DEL/2025[2013-14]Status: DisposedITAT Delhi30 Sept 2025AY 2013-14

Bench: Shri M. Balaganesh & Shri Sudhir Kumaracit, Vs. M/S. Jkm Infra Projects Ltd, Central Circle-19, Sector-9, Noida Delhi Maharishinagar, Maharishi Nagar, So Gautam Budh Nagar, Up 201304 (Appellant) (Respondent) Pan: Aabcj3577H Co 132/Del/2025 (In Ita No. 3031/Del/2025) (Assessment Year: 2013-14) M/S. Jkm Infra Projects Ltd, Vs. Acit, Sector-9, Noida Central Circle-19, Maharishinagar, Maharishi Delhi Nagar, So Gautam Budh Nagar, Up 201304 (Appellant) (Respondent) Pan: Aabcj3577H

For Appellant: Shri Ved Jain, AdvFor Respondent: Shri Om Prakash, Sr. DR
Section 143(3)Section 147Section 148Section 149Section 149(1)Section 149(1)(b)

India. It has been unearthed that Idemia India and its group entities have deployed various mechanisms through which it is shifting profit to their Associated Enterprises (AEs) especially Idemia France SAS and Idemia Germany GmBH. Investigation have revealed various tax-avoiding arrangements operated by the group entities like export sales ... filed for F. Y. 201516 relevant to A. Y. 2016-17 by way of various tax-avoiding arrangements and shifting profits to their Associated Enterprises (AEs) outside India. Therefore, as specified u/s 149(l)(b) of the Income-tax Act, 1961 read CO 132/Del/2025 M/s. JKM Infra Projects Ltd with

Concentrix Cvg Customer Management Group Inc., United States of America vs. Assistant Commissioner of Income Tax, Circle 1(2)(1), International Taxation, Delhi

In the result, the assessee’s both appeals are allowed as above

ITA 1892/DEL/2025[2022-23]Status: DisposedITAT Delhi30 Sept 2025AY 2022-23

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraita 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)

Section 234ASection 270A

services. Convergys Indian Services Pvt. Ltd. (‘CIS’) is a subsidiary of the assessee company in India. The assessee takes services of CIS, its Indian Associate Enterprise (‘AE’), for its overseas customers. The CIS provides IT enabled services i.e. call Centre and back-office services in the relevant year ... assessees. To what extent and when ―place of management‖ principle will be applicable in such cases, DTAA which will be applicable as the associated enterprise were located in UK and Australia and computation of income attributable to the PE are highly debatable and contentious questions which require findings of facts

ACIT, Circle 1(2)(1), International Taxation, New Delhi vs. Concentrix Cvg Customer Management Group Inc., Usa

In the result, the assessee’s both appeals are allowed as above

ITA 724/DEL/2023[2019-20]Status: DisposedITAT Delhi30 Sept 2025AY 2019-20

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraita 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)

Section 234ASection 270A

services. Convergys Indian Services Pvt. Ltd. (‘CIS’) is a subsidiary of the assessee company in India. The assessee takes services of CIS, its Indian Associate Enterprise (‘AE’), for its overseas customers. The CIS provides IT enabled services i.e. call Centre and back-office services in the relevant year ... assessees. To what extent and when ―place of management‖ principle will be applicable in such cases, DTAA which will be applicable as the associated enterprise were located in UK and Australia and computation of income attributable to the PE are highly debatable and contentious questions which require findings of facts

Concentrix Cvg Customer Management Group Inc., United States vs. ACIT, (Int.Taxation) 1(2)(1), New Delhi

In the result, the assessee’s both appeals are allowed as above

ITA 668/DEL/2023[2019-20]Status: DisposedITAT Delhi30 Sept 2025AY 2019-20

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraita 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)

Section 234ASection 270A

services. Convergys Indian Services Pvt. Ltd. (‘CIS’) is a subsidiary of the assessee company in India. The assessee takes services of CIS, its Indian Associate Enterprise (‘AE’), for its overseas customers. The CIS provides IT enabled services i.e. call Centre and back-office services in the relevant year ... assessees. To what extent and when ―place of management‖ principle will be applicable in such cases, DTAA which will be applicable as the associated enterprise were located in UK and Australia and computation of income attributable to the PE are highly debatable and contentious questions which require findings of facts

Concentrix Cvg Customer Management Group Inc., United States vs. ACIT, (Int.Taxation) 1(2)(1), New Delhi

In the result, the assessee’s both appeals are allowed as above

ITA 667/DEL/2023[2018-19]Status: DisposedITAT Delhi30 Sept 2025AY 2018-19

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraita 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)

Section 234ASection 270A

services. Convergys Indian Services Pvt. Ltd. (‘CIS’) is a subsidiary of the assessee company in India. The assessee takes services of CIS, its Indian Associate Enterprise (‘AE’), for its overseas customers. The CIS provides IT enabled services i.e. call Centre and back-office services in the relevant year ... assessees. To what extent and when ―place of management‖ principle will be applicable in such cases, DTAA which will be applicable as the associated enterprise were located in UK and Australia and computation of income attributable to the PE are highly debatable and contentious questions which require findings of facts

Concentrix Cvg Customer Management Group Inc., United States of America vs. Assistant Commissioner of Income-Tax (International Taxation)- 1(2)(1), New Delhi

In the result, the assessee’s both appeals are allowed as above

ITA 3512/DEL/2023[2021-22]Status: DisposedITAT Delhi30 Sept 2025AY 2021-22

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraita 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)

Section 234ASection 270A

services. Convergys Indian Services Pvt. Ltd. (‘CIS’) is a subsidiary of the assessee company in India. The assessee takes services of CIS, its Indian Associate Enterprise (‘AE’), for its overseas customers. The CIS provides IT enabled services i.e. call Centre and back-office services in the relevant year ... assessees. To what extent and when ―place of management‖ principle will be applicable in such cases, DTAA which will be applicable as the associated enterprise were located in UK and Australia and computation of income attributable to the PE are highly debatable and contentious questions which require findings of facts

ACIT, International Taxation, Circle-1(2)(1), New Delhi vs. Concentrix Cvg Customer Management Group Inc., United State of America

In the result, the assessee’s both appeals are allowed as above

ITA 1281/DEL/2022[2017-18]Status: DisposedITAT Delhi30 Sept 2025AY 2017-18

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraita 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)

Section 234ASection 270A

services. Convergys Indian Services Pvt. Ltd. (‘CIS’) is a subsidiary of the assessee company in India. The assessee takes services of CIS, its Indian Associate Enterprise (‘AE’), for its overseas customers. The CIS provides IT enabled services i.e. call Centre and back-office services in the relevant year ... assessees. To what extent and when ―place of management‖ principle will be applicable in such cases, DTAA which will be applicable as the associated enterprise were located in UK and Australia and computation of income attributable to the PE are highly debatable and contentious questions which require findings of facts

Concentrix Cvg Customer Management Group Inc., Delhi vs. DCIT Circle-1(2)(1)International Taxation, Delhi

In the result, the assessee’s both appeals are allowed as above

ITA 1086/DEL/2022[2017-18]Status: DisposedITAT Delhi30 Sept 2025AY 2017-18

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraita 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)

Section 234ASection 270A

services. Convergys Indian Services Pvt. Ltd. (‘CIS’) is a subsidiary of the assessee company in India. The assessee takes services of CIS, its Indian Associate Enterprise (‘AE’), for its overseas customers. The CIS provides IT enabled services i.e. call Centre and back-office services in the relevant year ... assessees. To what extent and when ―place of management‖ principle will be applicable in such cases, DTAA which will be applicable as the associated enterprise were located in UK and Australia and computation of income attributable to the PE are highly debatable and contentious questions which require findings of facts

Convergys Customer Management Group Inc., New Delhi vs. DCIT, Circle- 1(2)(1), International Taxation, New Delhi

In the result, the assessee’s both appeals are allowed as above

ITA 7924/DEL/2018[2014-15]Status: DisposedITAT Delhi30 Sept 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraita 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)

Section 234ASection 270A

services. Convergys Indian Services Pvt. Ltd. (‘CIS’) is a subsidiary of the assessee company in India. The assessee takes services of CIS, its Indian Associate Enterprise (‘AE’), for its overseas customers. The CIS provides IT enabled services i.e. call Centre and back-office services in the relevant year ... assessees. To what extent and when ―place of management‖ principle will be applicable in such cases, DTAA which will be applicable as the associated enterprise were located in UK and Australia and computation of income attributable to the PE are highly debatable and contentious questions which require findings of facts

DCIT, Circle- 1(1)(1), International Taxation, New Delhi vs. Convergys Customer Management Group Inc., New Delhi

In the result, the assessee’s both appeals are allowed as above

ITA 130/DEL/2018[2013-14]Status: DisposedITAT Delhi30 Sept 2025AY 2013-14

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraita 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)

Section 234ASection 270A

services. Convergys Indian Services Pvt. Ltd. (‘CIS’) is a subsidiary of the assessee company in India. The assessee takes services of CIS, its Indian Associate Enterprise (‘AE’), for its overseas customers. The CIS provides IT enabled services i.e. call Centre and back-office services in the relevant year ... assessees. To what extent and when ―place of management‖ principle will be applicable in such cases, DTAA which will be applicable as the associated enterprise were located in UK and Australia and computation of income attributable to the PE are highly debatable and contentious questions which require findings of facts

Convergys Customer Management Group Inc., New Delhi vs. DCIT, Circle- 1(2)(1), International Taxation, New Delhi

In the result, the assessee’s both appeals are allowed as above

ITA 7727/DEL/2017[2013-14]Status: DisposedITAT Delhi30 Sept 2025AY 2013-14

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraita 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)

Section 234ASection 270A

services. Convergys Indian Services Pvt. Ltd. (‘CIS’) is a subsidiary of the assessee company in India. The assessee takes services of CIS, its Indian Associate Enterprise (‘AE’), for its overseas customers. The CIS provides IT enabled services i.e. call Centre and back-office services in the relevant year ... assessees. To what extent and when ―place of management‖ principle will be applicable in such cases, DTAA which will be applicable as the associated enterprise were located in UK and Australia and computation of income attributable to the PE are highly debatable and contentious questions which require findings of facts