https://www.taxtmi.com/caselaws?id=435325 The Tribunal upheld that M/s. Convergys India Services Pvt. Ltd. (CIS) constituted a Permanent Establishment (PE) of the assessee in India. Profit attribution methodology was directed to be followed as per previous years. IPLC charges were held not taxable as royalty in India. The existence of a Dependent Agent PE and Service PE in India was dismissed. The Tribunal dismissed the revenue's appeal and partly allowed the assessee's appeal, emphasizing judicial discipline and consistency. en-us Mon, 06 Mar 2023 00:00:00 +0530 Thu, 16 Mar 2023 14:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=435325 The Tribunal upheld that M/s. Convergys India Services Pvt. Ltd. (CIS) constituted a Permanent Establishment (PE) of the assessee in India. Profit attribution methodology was directed to be followed as per previous years. IPLC charges were held not taxable as royalty in India. The existence of a Dependent Agent PE and Service PE in India was dismissed. The Tribunal dismissed the revenue's appeal and partly allowed the assessee's appeal, emphasizing judicial discipline and consistency. Case-Laws Income Tax Mon, 06 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=435325