In a landmark ruling, the Hon’ble Delhi High Court (“Delhi HC”) has held that profits generated by a Permanent Establishment (PE) in India shall be liable to tax in India, even if the parent enterprise has incurred losses on a
India Tax Law
The India Tax Law blog, published by Cyril Amarchand Mangaldas, focuses on developments and analyses in Indian taxation, including the impact of new labour codes on tax liabilities, interpretations of Double Taxation Avoidance Agreements (DTAAs) and Multilateral Instruments (MLI), reforms in profit attribution rules for Permanent Establishments (PEs), and clarifications on General Anti-Avoidance Rules (GAAR). It covers tax implications for both domestic and foreign investors, litigation strategies, regulatory updates, and policy reforms affecting corporate and individual taxpayers. The blog addresses practical tax planning, compliance challenges, and judicial decisions shaping the Indian tax landscape.
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First judgment on GAAR holds bonus-stripping to be an impermissible tax-avoidance arrangement
Delhi HC delivers an important pronouncement on permanent establishment
Premium Received on Redemption of Debentures: Taxed as Interest or Capital Gains?
Taxation landscape of Global Capability Centres (GCCs) in India
In part IV of our series on key legal consideration for establishing global capability centres (“GCCs”) in India,[1] we discuss the key taxation issues that foreign companies must be aware of ahead of setting up its operations in India.…
Google Adwords program is not taxable as either “royalty” or “Fee for technical services” in India
The Income Tax Appellate Tribunal, Bangalore (“Tribunal”), recently in Google Ireland Ltd. v. DCIT[1] allowed an appeal by Google Ireland Ltd (“Google Ireland”) and held that the payments received from Google India Pvt Ltd (“Google India”) for granting marketing…


