Judgment briefs
Supreme Court of India

Hyatt International Southwest Asia Ltd v. Additional Director of Income Tax

Income Tax Act, 1961 – ss. 92F(iii-a), 143(3) – Double Taxation Avoidance Agreement (Indo-UAE)

Dismissed
Court
Supreme Court of India
Decided
24 Jul 2025
Citation
[2025] 7 S.C.R. 1497
Case no.
CIVIL APPEAL No. 9766/2025
Bench
J.b. Pardiwala, R Mahadevan

Issue for consideration

Issue arose whether the appellant, a tax resident of the UAE, has a Permanent Establishment-PE in India u/Art.5(1) of the Indo-UAE Double Taxation Avoidance Agreement-DTAA, and consequently, whether its income derived under the Strategic Oversight in India.

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