DTAA | Subsidiary Of A Company Does Not Ipso Facto Constitute Its Permanent Establishment: Delhi High Court

The Delhi High Court has ruled that a subsidiary of a company does not ipso facto constitute its permanent establishment under a DTAA. This decision clarifies the interpretation of permanent establishment in international tax agreements. It ensures that tax rules are applied correctly. This ruling underscores the need for clear guidelines on DTAA. It emphasizes the importance of fair assessments. The High Court's order protects the rights of taxpayers.