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.”
Justice Vinod Kumar
Delhi HC slams Income Tax Department for 8-Year delay in Refund to Microsoft; orders refund of ₹5.37 Crore with interest
Income Tax Department officers’ “utterly negligent attitude” compelled the petitioner to approach the Court.
Part of ICC Sponsorship Payments, for using ICC Trademark, constitutes Taxable Royalty: Delhi High Court
The Court held that the revisional authority was justified in concluding that the payment had two distinct elements, i.e., advertisement and trademark usage.