Profits Attributable to Permanent Establishment Cannot Be Overlooked Based on Global Income or Loss of Cross-Border Entity: Delhi High Court

In a landmark judgment regarding the Double Taxation Avoidance Agreement (DTAA) between the United Arab Emirates and India, the Delhi High Court has provided significant clarity on how profits attributed to a Permanent Establishment (PE) should be taxed. This ruling emphasizes the independence of a PE in taxation matters. Key Highlights of the Judgment: 1. Background of the Case: The petitioner, Hyatt International Southwest Asia, challenged previous interpretations of profit…