Permanent Establishment (PE) taxable as Independent Entity: Delhi HC in Hyatt International Case [Read Order]
The court ruled that the PE in India should be treated as a distinct and separate taxable entity, independent from the enterprise’s global profit or loss situation.
By Manu Sharma - On September 24, 2024 10:47 am - 2 mins read
The Delhi High Court has held that a Permanent Establishment (PE) should be taxed as an independent entity, regardless of the global financial performance of the enterprise to which the PE belongs. The case revolved around whether income could be attributed to a PE in India if the parent entity suffered losses globally. The appellant…
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