Source State’s Right to Attribute Income to a PE Based on Global Income/Loss

Hyatt International Southwest Asia Ltd Vs Additional Director of Income Tax (Delhi High Court) Source State’s right to attribute income to a Permanent Establishment (PE) based solely on the global income or loss incurred by a cross-border entity – With reference to the Hyatt International Southwest Asia Ltd Case The Delhi High Court has emphatically held that Article 7 does not restrict the source State’s right to attribute income to a Permanent Establishment (PE) based solely on the global income or loss incurred by a cross-border entity through its judgement in Hyatt Internati...