Assessee is  an American company engaged in providing IT enabled customer management services by utilizing its advanced information system capabilities, human resource management skills and industrial experience. It had a subsidiary in India by name ‘CIS’ which provided call centre/back office support service to its Indian customers  CIS was practically projection of assessee’s business in India and carried out its business under control and guidance of assessee without assuming any significant risk in relation to such functions-Employees of assessee frequently visited premises of CIS to provide supervision, direction and control over operations of CIS. The  assessee had a fixed place PE in India under article 5(1) of DTAA. Attribution of profit PE is taxable in India. (AY. 2014-15)