Supreme Court · 2025 INSC 891 · Decided 24 July 2025
Hyatt International Southwest Asia LTD v. Additional Director of Income Tax
- Court
- Supreme Court of India
- Citation
- 2025 INSC 891 · [2025] 7 S.C.R. 1497
- Case number
- CIVIL APPEAL No. 9766/2025
- Decided
- 24 July 2025
- Bench
- J.B. PARDIWALA, R MAHADEVAN (2-judge bench)
- Outcome
- Dismissed
- Case type
- Civil
- Acts & sections cited
- Constitution; Income Tax Act Section 92F
Headnote
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. Income Tax Act, 1961 - ss. 92F(iii-a), 143(3) - Double Taxation Avoidance Agreement (Indo-UAE) - Arts. 4, 5(1), 7 - Strategic Oversight Services Agreement-SOSA - Art. I to V - Permanent Establishment-PE - Appellant company
Judgments are the courts' own published copies, provided for study; they are not certified copies. Source: Indian Supreme Court & High Court Judgments, Dattam Labs (CC-BY-4.0)