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#permanent establishment

Every article filed under the “permanent establishment” tag — analysis, news and updates.

215 articles
Income TaxOffshore Supply Non-Taxable as No PE Was Proven in India: ITAT Delhi
Income Tax

Offshore Supply Non-Taxable as No PE Was Proven in India: ITAT Delhi

Adv (CA) Vijay Gupta10 months ago
Income TaxSC Defines PE Beyond Physical Presence: Hyatt International Ruling Explained
Income Tax

SC Defines PE Beyond Physical Presence: Hyatt International Ruling Explained

Purshottam Mishra10 months ago
Income TaxDeductions Allowed Even Without Active PE: SC Clarifies Business Continuity for Non-Residents
Income Tax

Deductions Allowed Even Without Active PE: SC Clarifies Business Continuity for Non-Residents

CA Prosenjit Sett10 months ago
Goods and Services TaxGST and Income Tax on Software Purchases from Foreign Vendors Without PE in India
Goods and Services Tax

GST and Income Tax on Software Purchases from Foreign Vendors Without PE in India

CA PRABHAKAR GUPTA - Indian Tax Update11 months ago
Income TaxLease income held as business profit, not royalty under India–Ireland DTAA without PE
Income Tax

Lease income held as business profit, not royalty under India–Ireland DTAA without PE

Chambers of Sudarshan Roy11 months ago
Income TaxSC Expands Fixed Place PE: Effective Control Over Physical Presence
Income Tax

SC Expands Fixed Place PE: Effective Control Over Physical Presence

Abhinarayan Mishra FCA, FCS, LL.B, IP, RV, SA11 months ago
Income TaxNo Office, No Expatriates, No PE: ITAT Delhi Rejects Revenue’s Repeated PE Allegation
Income Tax

No Office, No Expatriates, No PE: ITAT Delhi Rejects Revenue’s Repeated PE Allegation

CA Vijayakumar Shetty12 months ago
Income TaxHyatt PE Case: SC Upholds ‘Disposal Test’ under India-UAE DTAA
Income Tax

Hyatt PE Case: SC Upholds ‘Disposal Test’ under India-UAE DTAA

Sarthak Mishra12 months ago
Income TaxNo Fixed Place, Service PE or DAPE: ITAT Delhi Holds No PE in India, Profit Attribution Quashed
Income Tax

No Fixed Place, Service PE or DAPE: ITAT Delhi Holds No PE in India, Profit Attribution Quashed

CA Vijayakumar Shetty1 year ago
Income TaxDisposal Test or Disposal Trap? How Hyatt Turned Oversight into Permanent Establishment
Income Tax

Disposal Test or Disposal Trap? How Hyatt Turned Oversight into Permanent Establishment

Arnav Mathur1 year ago
Income TaxNo Section 40(a)(i) Disallowance for Purchases from Foreign AEs without PE in India: Delhi HC
Income Tax

No Section 40(a)(i) Disallowance for Purchases from Foreign AEs without PE in India: Delhi HC

CA Vijayakumar Shetty1 year ago
Income TaxITAT Mumbai Cuts Through the Rough: No Attribution Without PE
Income Tax

ITAT Mumbai Cuts Through the Rough: No Attribution Without PE

CA Vijayakumar Shetty1 year ago
Income TaxNo PE in India for Irish Aircraft Lessor – Lease Rentals Taxable Only in Ireland under DTAA
Income Tax

No PE in India for Irish Aircraft Lessor – Lease Rentals Taxable Only in Ireland under DTAA

CA Sandeep Kanoi1 year ago
Income TaxFunctional control over core Indian operations constitutes a Fixed Place PE: SC
Income Tax

Functional control over core Indian operations constitutes a Fixed Place PE: SC

CA Rakhi Thakur1 year ago