[ compiled answer ]
law as at 14 Aug 2026 · judicial
What did e-Funds hold about outsourcing to an Indian subsidiary?
The compiled answer
Outsourcing work to India does not of itself give rise to a fixed place PE — ADIT v. E-Funds IT Solution Inc, (2018) 13 SCC 294 (SC). A subsidiary's premises are not ipso facto at the parent's disposal, and the burden of establishing a PE lies initially on the Revenue.
Pinpoint
ADIT v. E-Funds IT Solution Inc, (2018) 13 SCC 294 (SC), para 16
String-verified quote
“This outsourcing of work to India would not give rise to a fixed place PE and the High Court judgment is, therefore, correct on this score.”
source: ledger:E-FUNDS — verified at load; a quote that stops matching its source is a compile error
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