Substance Check for PE Determination

1

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Substance Check

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

Substance Check for PE Determination

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sudheer kumar
hyderabad , India