July 24, 2025, Hyatt International Southwest Asia Ltd (“Taxpayer”), the Honourable Supreme Court (“SC”) upheld the Delhi High Court's judgment on Taxpayer’s existence of a Fixed Place Permanent Establishment (“PE”) in India.

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The Hon’ble ITAT held that once it is established that GAGIL FDI Limited (‘assessee’) is carrying its business activities in Cyprus and holds a valid Tax Residency Certificate (‘TRC’) issued by Revenue Authority at Cyprus, it is not merely a pass through entity.