Permanent Establishment: A Recent Decision of Hon’ble Supreme Court

Advocate Akhilesh Kumar Sah Section 9 of the Income Tax Act, 1961(for short ‘the Act’) deals with the income deemed to accrue or arise in India and as per section 9(1) “permanent establishment” shall have the meaning assigned to it in clause (iiia) of section 92F of the Act. Clause (iiia) of section 92F incorporates that “permanent establishment”(PE) referred to in clause(iii), includes a fixed place of business through which the business of the enterprise is wholly or partly carried on. Recently, in Formula One World Championship Ltd. vs. CIT, International Taxation (Civil Appea...