Permanent Establishment Under DTAAs: Judicial Trends and Evolving Interpretations
In international tax, one of the most important and often debated concepts is Permanent Establishment, or PE. This determines whether a country has...
![Indian Subsidiary’s Classification as Dependent Agent PE in Software Sales: ITAT Sets Aside AO’s Decision [Read Order]](https://www.taxscan.in/wp-content/uploads/2025/02/Indian-Subsidiary-Software-Sales-Agent-PE-taxscan.jpg "Indian Subsidiary’s Classification as Dependent Agent PE in Software Sales: ITAT Sets Aside AO’s Decision [Read Order]")
![Bandwidth Charges Exempt from TDS as They Do Not Constitute Royalty: ITAT Favors Bharti Airtel Ltd [Read Order]](https://www.taxscan.in/wp-content/uploads/2024/10/ITAT-Income-Tax-Appellate-Tribunal-ITAT-delhi-Bandwidth-Charge-TDS-ax-Deducted-at-Source-Bharti-Airtel-Ltd-TAXSCAN.jpeg "Bandwidth Charges Exempt from TDS as They Do Not Constitute Royalty: ITAT Favors Bharti Airtel Ltd [Read Order]")
![Distribution Revenue from US Broadcasting Company not Taxable as “Royalty” under India-US DTAA [Read Order]](https://www.taxscan.in/wp-content/uploads/2024/09/Income-Tax-India-US-DTAA-US-broadcasting-company-tax-TAXSCAN.jpg "Distribution Revenue from US Broadcasting Company not Taxable as “Royalty” under India-US DTAA [Read Order]")
![Subscription Fees from cloud Services not Taxable as Royalty in India under India-Ireland DTAA: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2024/08/WhatsApp-Image-2024-08-29-at-15.32.18_72802c46.jpg "Subscription Fees from cloud Services not Taxable as Royalty in India under India-Ireland DTAA: ITAT [Read Order]")
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...
![Liaison Office of Non Resident Printing Entity in India can treated as PE under Article 5(2) India-Germany DTAA: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2024/03/ITAT-ITAT-Delhi-Income-Tax-Permanent-Establishment-India-Germany-DTAA-Liaison-office-tax-taxscan.jpg "Liaison Office of Non Resident Printing Entity in India can treated as PE under Article 5(2) India-Germany DTAA: ITAT [Read Order]")
![CESTAT Annual Digest - [Part - 23]](https://www.taxscan.in/wp-content/uploads/2024/01/Annual-Digest-2023-CESTAT-Annual-Digest-2023-cestat-TAXSCAN-3.jpg "CESTAT Annual Digest - [Part - 23]")
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...
Relief to Gemological Institute of America, Indian Subsidiary Operating Independent manner does not Constitute PE: ITAT [Read More]
The Mumbai Bench of Income Tax Appellate Tribunal (ITAT) has granted relief to the Gemological Institute of America, as the Indian subsidiary operating in an independent manner would not constitute a...
![Relief to Gemological Institute of America, Indian Subsidiary Operating Independent manner does not Constitute PE: ITAT [Read More]](https://www.taxscan.in/wp-content/uploads/2023/09/Relief-Gemological-Institute-America-Indian-Subsidiary-Operating-Independent-manner-Constitute-PE-ITAT-taxscan.jpg "Relief to Gemological Institute of America, Indian Subsidiary Operating Independent manner does not Constitute PE: ITAT [Read More]")
Dividend income from Indian Entities in Oman Treated as PE under Omani Tax Laws, Not Taxable in India: Supreme Court [Read Order]
The Supreme Court has held that dividend income from Indian entities in Oman is treated as a Permanent Establishment (PE) under Omani tax laws and is not taxable in India. M/s Krishak Bharti...
![Dividend income from Indian Entities in Oman Treated as PE under Omani Tax Laws, Not Taxable in India: Supreme Court [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/09/Dividend-income-Indian-Entities-Oman-Treated-PE-Omani-Tax-Laws-Not-Taxable-Supreme-Court-taxscan.jpg "Dividend income from Indian Entities in Oman Treated as PE under Omani Tax Laws, Not Taxable in India: Supreme Court [Read Order]")
Relief to Amazon Web Services India: Delhi HC reduces Liability to Withhold Tax for TDS from 16% to 8% w.r.t. Payment to AWS USA [Read Order]
In a recent decision, the High Court of Delhi has modified its earlier order in the case of Amazon Web Services India Pvt Ltd & Anr. vs. Income Tax Officer & Anr. The case pertains to a...
