Commissioner Of Income Tax, ... vs Clifford Chance Pte Ltd

ik-49577126 Delhi High Court 4 December 2025 • 35 min read

Judges (2)

V. Kameswar Rao Delivered Vinod Kumar Coram

Counsel (8)

Adityya Vohra Counsel Respondent Ajay Vohra Counsel Respondent Ashvini Kr Counsel Appellant Gibran Counsel Appellant Kunal Pandey Counsel Respondent Puneet Rai Counsel Appellant Rishabh Nangia Counsel Appellant Tanmay Counsel Respondent

Parties (2)

Clifford Chance Pte Ltd Respondent Commissioner of Income Tax, International Taxation-1, New Delhi Appellant

Case Significance

Commissioner Of Income Tax, ... vs Clifford Chance Pte Ltd is a Delhi High Court decision dated December 4, 2025 (citation: ik-49577126). The Revenue appealed under Section 260A of the Income-Tax Act against an ITAT order allowing the appeals of Clifford Chance Pte Ltd, a non-resident legal advisory firm, for AY 2020-21 and 2021-22, on the question of whether the assessee had a permanent establishment in India. The Court examined whether the firm's use of its Indian affiliate's premises and staff constituted a fixed place PE or dependent agent PE, and whether its website constituted a PE. The appeals were dismissed, with the Co The bench comprised Justices V. Kameswar Rao and Vinod Kumar. The judgment was delivered by Justice V. Kameswar Rao.

Summary

The Revenue appealed under Section 260A of the Income-Tax Act against an ITAT order allowing the appeals of Clifford Chance Pte Ltd, a non-resident legal advisory firm, for AY 2020-21 and 2021-22, on the question of whether the assessee had a permanent establishment in India. The Court examined whether the firm's use of its Indian affiliate's premises and staff constituted a fixed place PE or dependent agent PE, and whether its website constituted a PE. The appeals were dismissed, with the Court affirming the ITAT's finding that no permanent establishment existed in India.

What was the outcome of Commissioner Of Income Tax, ... vs Clifford Chance Pte Ltd?

The Revenue appealed under Section 260A of the Income-Tax Act against an ITAT order allowing the appeals of Clifford Chance Pte Ltd, a non-resident legal advisory firm, for AY 2020-21 and 2021-22, on ...

Judgment

Read the full judgment on the official India Courts portal.

Read on Indian Kanoon

Source: Indian Kanoon (ik-49577126)