{"url":"https://lrlabs.ai/t/efunds_outsourcing_holding","engine":"deterministic","llm_in_path":false,"id":"efunds_outsourcing_holding","question":"What did e-Funds hold about outsourcing to an Indian subsidiary?","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","confidence":"judicial","as_at":"14 Aug 2026","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.","quote_string_verified":true,"quote_source":"ledger:E-FUNDS"}