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ITAT Quashes ₹3960+ Crore Tax Demand Against Booking.com, Rules No Permanent Establishment in India [Read Order]

In a recent ruling The Income Tax Appellate Tribunal (ITAT) Delhi has set aside a tax demand of over ₹3960 crore, holding that the Netherlands‑based...

Virtual Service PE Not Recognised under DTAA: Delhi HC Rules in Clifford Chance Case [Read...

Overriding effect of Article 5(3) of DTAA: Supreme Court Adjourns Hearing in Hyundai Heavy...

Permanent Establishment Under DTAAs: Judicial Trends and Evolving Interpretations

Indian Subsidiary’s Classification as Dependent Agent PE in Software Sales: ITAT Sets Aside AO’s...

Bandwidth Charges Exempt from TDS as They Do Not Constitute Royalty: ITAT Favors Bharti Airtel Ltd [Read Order]

The Delhi Bench of Income Tax Appellate Tribunal(ITAT) ruled in favor of Bharti Airtel Ltd., stating that bandwidth charges were exempt from Tax Deducted at Source (TDS) as they do not...

Distribution Revenue from US Broadcasting Company not Taxable as “Royalty” under India-US DTAA [Read Order]

In a significant ruling, the Income Tax Appellate Tribunal ( ITAT ) Delhi Bench has ruled that the distribution revenue received by Turner Broadcasting System Asia Pacific, Inc. ( TBSAP ), a...

Subscription Fees from cloud Services not Taxable as Royalty in India under India-Ireland DTAA: ITAT [Read Order]

In a recent ruling, the Income Tax Appellate Tribunal (ITAT) of Delhi held that subscription fees from cloud services are not taxable as royalty in India under the India -Ireland Double Taxation...

Liaison Office of Non Resident Printing Entity in India can treated as PE under Article 5(2) India-Germany DTAA: ITAT [Read Order]

The Delhi bench of Income Tax Appellate Tribunal ( ITAT ) held that liaison offices of non-resident printing entities in India could be treated as Permanent Establishment ( PE ) under Article 5(2) of...

CESTAT Annual Digest - [Part - 23]

This yearly digest analyzes all the CESTAT stories published in the year 2023 at taxscan.in Construction of Complex by Cooperative Housing Society to its Members is not Liable to Service Tax:...

No Profit can be Attributed if Commission Paid to Ricardo India is Adjusted Against Profit Attributed to PE: Delhi HC [Read Order]

In a landmark decision, the Delhi High Court has ruled that no additional profit can be attributed to the Permanent Establishment (PE) of a UK-based company operating in India when adjusting the...

Commission Paid - Profit - Ricardo India - Permanent Establishment - delhi high court - delhi hc - TAXSCAN

Understanding Permanent Establishment in International Taxation: Key Concepts and Implications

Recent years have seen India become one of the fastest developing nations in the world, with increased economic activity brought about by significant inflows of foreign investment and technology...