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Hyatt international has PE in India hence income attributable is taxable in India
Case Law Details
- Case Name
- Hyatt International Southwest Asia Ltd. Vs Additional Director of Income Tax (Supreme Court of India)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- Supreme Court of India
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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 under Article 4 of the ...
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