Supreme Court rules Hyatt had a ‘Permanent Establishment’ under DTAA, making its India-sourced income taxable despite global losses. Tax liability upheld for operations through Indian hotel partnerships.
The Delhi High Court dismissed the Income Tax department’s claim that fees from LexisNexis were taxable as “royalties.” It emphasized that subscribing to a legal database does not transfer copyright. The Court ruled in favor of Relx Inc., stating that accessing the database does not constitute technical consultancy services, upholding the ITAT’s decision.
