Author: Ameet Baid, Virti Shah & Lathika S kumari, ASA
In this article, the Delhi High Court ruling in Clifford Chance Pte. Ltd. v. CIT is analysed, clarifying that a Service Permanent Establishment arises only when services are physically performed in India. It highlights that virtual or remote delivery of services cannot trigger a PE under the India–Singapore DTAA, reinforcing strict treaty interpretation and providing clarity for multinational service providers.
Published on – Taxmann
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