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Samsung India Not Permanent Establishment of Samsung Korea: Delhi HC
Case Law Details
- Case Name
- PCIT Vs Samsung Electronics Co. Ltd. (Delhi High Court)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- All High Courts, Delhi High Court
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PCIT Vs Samsung Electronics Co. Ltd. (Delhi High Court)
The Delhi High Court ruled that Samsung India Electronics Pvt. Ltd. (SIEL), a wholly owned subsidiary of Samsung Electronics Co., Korea, does not qualify as a ‘Permanent Establishment’ (PE) of its parent company in India under the India-Korea Double Tax Avoidance Agreement (DTAA). Consequently, Samsung Korea cannot be taxed in India for the business activities carried out by SIEL. This decision was rendered by a bench of Justices Yashwant Varma and Harish Vaidyanathan Shankar, which upheld the findings of the Income Tax Appe...
