https://www.taxtmi.com/caselaws?id=775691 A fixed place Permanent Establishment existed in India where the enterprise had the hotel premises at its disposal under long-term contractual arrangements and exercised continuing control over strategic, operational, staffing, procurement, pricing, branding and financial matters. Applying Article 5(1) of the India-UAE DTAA and the disposal test, the premises were used for core business functions rather than merely auxiliary activities, so the separate management of the Indian entity did not negate the substantive operational nexus. As a result, income received under the Strategic Oversight Services Agreements was attributable to the Permanent Establishment and taxable in India under Article 7(1). en-us Thu, 24 Jul 2025 00:00:00 +0530 Fri, 25 Jul 2025 10:33:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775691 A fixed place Permanent Establishment existed in India where the enterprise had the hotel premises at its disposal under long-term contractual arrangements and exercised continuing control over strategic, operational, staffing, procurement, pricing, branding and financial matters. Applying Article 5(1) of the India-UAE DTAA and the disposal test, the premises were used for core business functions rather than merely auxiliary activities, so the separate management of the Indian entity did not negate the substantive operational nexus. As a result, income received under the Strategic Oversight Services Agreements was attributable to the Permanent Establishment and taxable in India under Article 7(1). Case-Laws Income Tax Thu, 24 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775691