Know why Delhi High Court rejected Virtual Service PE to Clifford Chance under DTAA
“The words ‘within a Contracting State’ in Article 5(6) mandate a physical footprint and cannot be expanded to include virtual service permanent establishments.”
“The words ‘within a Contracting State’ in Article 5(6) mandate a physical footprint and cannot be expanded to include virtual service permanent establishments.”
Infifresh Foods Private Limited operating under brand name ‘Captain Fresh’ (CF India) and its overseas subsidiary Infifresh Foodtech AS