Profits Attributable To Permanent Establishment Can't Be Ignored On Basis Of Global Income Or Loss Earned/ Incurred By Cross Border Entity: Delhi HC

The Delhi High Court ruled on the tax implications of income allocation between India and the UAE under the Double Tax Avoidance Agreement (DTAA). The court clarified that holding companies in India have the right to attribute income to their permanent establishments in the UAE, ensuring that income tax is levied only in the country where the economic activity took place. This ruling provides important clarification for multinational companies operating between India and the UAE, reaffirming their rights to avoid double taxation under the treaty.