Income Tax, HC Delhi Judgement Dated 17/12/2025 – Outsourcing solutions to Indian subsidiary doesn’t result in creation of PE 

Case of CIT (International) vs EXL Service.Com, HC Delhi Judgement Dated 17^th December 2025. HC held that outsourcing solutions including transaction processing services and Internet/voice-based customer care services for its clients to subsidiary in India does not result in creation of Permanent Establishment (PE) in India under India-USA DTAA. 

(Link: HC Delhi Judgement Dated 17/12/2025)