Alleged Permanent Establishment in India of the Appellant under Article 5(1) and 5(2)(T) of the India - UAE Tax Treaty

Last updated: 11 August 2021
Quick Summary
This Income Tax Appellate Tribunal case concerns Hyatt International Southwest Asia Ltd. and its alleged Permanent Establishment (PE) in India under the India-UAE Tax Treaty. The tribunal noted that the core issue regarding the PE was already decided in favour of the assessee for a previous assessment year. Consequently, the matter of profit attribution to the PE was sent back to the Assessing Officer for reconsideration in line with the tribunal's previous directions, ensuring the assessee is given a fair hearing.

Court :
ITAT Delhi

Brief :
The present appeal by the assessee is directed against the order dated 28.07.2017 passed by the Assistant Commissioner of Income Tax, Circle-2(1)(1), International Taxation, New Delhi.

Citation :
ITA No.6179/Del/2017

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