Description
In Hyatt International v. ADIT (2025), the Supreme Court held that Hyatt had a Fixed Place PE in India under the India–UAE DTAA. The ruling emphasized substance over form—Hyatt’s sustained operational control and strategic involvement in Indian hotels created a taxable presence, despite no formal office or long-term employee stay.
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Substance Check for PE Determination
Taxability of Employee Stock Purchase | Scheme (‘ESPS’) in the hands of Employees
Stay of demand must consider merits and hardship, not rigid 20% pre-deposit
VCH - Global Transfer Pricing | Tax | Accounting | V-CFO