[Taxation Law] Market Research, Promotional Activities, Training Or Deployment Of Software Are 'Auxiliary Functions' Under DTAA: Delhi HC

The Delhi High Court has ruled on the taxation of market research, promotional activities, and training under the Double Taxation Avoidance Agreement (DTAA). The case examined whether income from these auxiliary functions, including the deployment of software, would be subject to taxation in India under the DTAA. The Court clarified that these activities do not automatically create a permanent establishment in India, and the income from them should not be taxed unless the activities meet specific conditions defined in the agreement. The judgment provides valuable insights into the application of DTAAs in the context of Indian taxation and its impact on foreign companies.