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Hyatt International Southwest Asia Ltd vs Assistant Director Of Income Tax on 22 December, 2023
cites
Article 7 in Constitution of India [Constitution]
Section 2 in The Income Tax Act, 1961 [Entire Act]
Article 5 in Constitution of India [Constitution]
Section 3 in The Income Tax Act, 1961 [Entire Act]
Section 4 in The Income Tax Act, 1961 [Entire Act]
Formula One World Championship Ltd vs Commissioer Of Income Tax, ... on 24 April, 2017
In Formula One
World Championship Ltd. v. Commissioner of Income Tax, International
Taxation-3, Delhi & Anr.1, the Supreme Court held that the appellant in
that case had a PE in India and had carried on its business through a
fixed place of business - Buddh International Circuit. The said track
was owned by Jaypee Sports International Ltd. (an Indian Company).
The appellant (Formula One World Championship Ltd.) had granted the
right to host the Formula One Grand Prix of India (event) to Jaypee
Sports International Ltd. The Supreme Court accepted the finding that
the appellant had full access through its personnel, to the said place
(Buddh International Circuit) and could also dictate who are authorized
to enter the areas reserved for it. Although, the said access was granted
only two weeks prior to the event and continued till one week
succeeding the date of event; the Court found that the appellant had
sufficient control in respect of the said premises to be construed as its
fixed place of business.