Hyatt international has PE in India hence income attributable is taxable in India

Hyatt International Southwest Asia Ltd. Vs Additional Director of Income Tax (Supreme Court of India)

Supreme Court held that Hyatt International has a fixed place Permanent Establishment in India within the meaning of Article 5(1) of the DTAA, and hence income received under Strategic Oversight Services Agreement [SOSA] attributable to such PE and is taxable in India.

Facts- The appellant is a company incorporated under the Companies Law, Dubai International Financial Centre Law No.3 of 2006, in the United Arab Emirates. It is a tax resident of the UAE unde

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