Compliance with India’s foreign investment regulations is now more critical than ever. The Enforcement Directorate has initiated a number of investigations, especially in the fintech, e-commerce and similar sectors, where the purpose of foreign investment is stated as information technology services but the money is channelled into restricted sectors. M&A and PE investments need to follow the substance over form principle in relation to use of funds. Please go through our PPT for more details.
Delhi ITAT rejects the “Back-Office = PE” equation
Download .pdf In the case of Concentrix CVG Customer Management Group, Inc. v. Deputy Commissioner of Income Tax (ITA No. 7727/Del/2017 & Ors., order dated September 30, 2025), the Income Tax Appellate Tribunal, Delhi (the “Delhi ITAT”), ruled that Concentrix CVG...