Delhi High Court Rules on Permanent Establishment Under India-Korea DTAA: "Mere Control by Parent Company Does Not Constitute a PE"; Dismisses Revenue Appeals Against Samsung Subsidiary for Lack of Fixed Place, Dependent Agent, or Service PE Evidence
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Delhi High Court Rules on Permanent Establishment Under India-Korea DTAA: “Mere Control by Parent Company Does Not Constitute a PE”; Dismisses Revenue Appeals Against Samsung Subsidiary for Lack of Fixed Place, Dependent Agent, or Service PE Evidence

Court’s Decision The Delhi High Court dismissed the appeals filed by the Revenue challenging the Income Tax Appellate Tribunal’s (ITAT) order. The court concluded that Samsung Electronics Co. Ltd.’s Indian…
January 25, 2025