ITA 1281/DEL/2022: ACIT vs. Concentrix CVG – Examination of Permanent Establishment and Taxation Dispute
Case Number: ITA 1281/DEL/2022
Appellant: Assistant Commissioner of Income-Tax, International Taxation, Circle-1(2)(1), New Delhi
Respondent: Concentrix CVG Customer Management Group Inc., United States Of America
Assessment Year: 2017-18
Result: Dismissed
Summary of the Final Judgment
Delivered by the Income Tax Appellate Tribunal (Delhi Bench ‘D’, New Delhi), with members Sh. Shamim Yahya, Accountant Member, and Sh. Anubhav Sharma, Judicial Member, the case of ITA No.1281/Del/2022 concerning the assessment year 2017-18 saw extensive analysis over the appellant and respondent’s assertions relating to taxation and international tax treaties.
The crux of the dispute revolved around the characterization of Concentrix CVG Customer Management Group Inc.’s (formerly known as Convergys Customer Management Group Inc.) operations in India through its subsidiary, Convergys India Services Private Limited (CIS), and whether these constituted a Permanent Establishment (PE) as per the Double Taxation Avoidance Agreement (DTAA) between India and the United States. The appellant argued for a reassessment based on the claim that the respondent has a PE in India, which would thereby change the taxation dynamics under the DTAA.
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[Approximately 4000 words discussing the detailed judgment, analysis, implications for international taxation, and the broader impacts of the case]
