Pr.Commissioner Of Income Tax vs Western Union Financial Services

ik-14089684 Delhi High Court 18 December 2024 • 107 min read

Judges (2)

Ravinder Dudeja Coram Yashwant Varma Delivered

Counsel (8)

Ajay Vohra Counsel Respondent Anant Mann Counsel Appellant Aseem Chawla Counsel Appellant Gaurav Jain Counsel Respondent Pratishtha Counsel Appellant Ruchir Bhatia Counsel Appellant Shalini Counsel Respondent Shubham Gupta Counsel Respondent

Parties (2)

Pr. Commissioner of Income Tax Appellant Western Union Financial Services Respondent

Case Significance

Pr.Commissioner Of Income Tax vs Western Union Financial Services is a Delhi High Court decision dated December 18, 2024 (citation: ik-14089684). This is a duplicate IK entry of the same Western Union PE case (ik-140392644). The Revenue appealed against ITAT orders holding Western Union's Indian liaison office did not constitute a Permanent Establishment under the India-USA DTAA. The court dismissed the batch of income tax appeals, holding the LO did not constitute a fixed place PE, DAPE, or software-based PE in India, with activities being auxiliary in character. The bench comprised Justices Ravinder Dudeja and Yashwant Varma. The judgment was delivered by Justice Yashwant Varma.

Summary

This is a duplicate IK entry of the same Western Union PE case (ik-140392644). The Revenue appealed against ITAT orders holding Western Union's Indian liaison office did not constitute a Permanent Establishment under the India-USA DTAA. The court dismissed the batch of income tax appeals, holding the LO did not constitute a fixed place PE, DAPE, or software-based PE in India, with activities being auxiliary in character.

What was the outcome of Pr.Commissioner Of Income Tax vs Western Union Financial Services?

Judgment

Read the full judgment on the official India Courts portal.

Read on Indian Kanoon

Source: Indian Kanoon (ik-14089684)