Content Provider | Supreme Court of India |
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e-ISSN | 30484839 |
Language | English |
Access Restriction | NDLI |
Subject Keyword | Income Tax Act 1961: |
Content Type | Text |
Resource Type | Law Judgement |
Jurisdiction | India |
Case Type | Appeal |
Court | Supreme Court of India |
Disposal Nature | Appeal Disposed Off |
Headnote | ncome Tax Act, 1961: c D E F G s. 1-95 - TDS on non-residents - Appellants-FOWC, UK Company (NRI), entered into Race Promotion Contract (RPC) with Jaypee Sports, Indian entity -: Grant of rights to Jaypee to host, stage and promote Formula One Grand Prix of India event at the Buddh International Circuit in India for a consideration of US$ 40 million - FOWC, if having any Permanent Establishment in India in terms of Art. 5 - Consideration received or receivable by FOWC from Jaypee, if subject to tax at source u!s. 195 - Held: FOWC is the Commercial Right Holder (CRH) - Buddh International Circuit is a fixed place where the commercial/economic activity of conducting F-1 Championship was carried out, and it was a virtual projection of foreign enterprise-FOWC in India - Fixed place of business in the form of physical location-Buddh International Circuit, was at the disposal of FOWC through which it conducted business, though for a short duration - Thus, FOWC had a Permanent Establishment in India - Taxable event took place in India and non-resident FOWC is liable to pay tax in India on the income it has earned in India - Since payments made by Jaypee to FOWC under RPC were business income of the FOWC through PE at Buddh International Circuit, and, thus, chargeable to tax, Jaypee bound to make appropriate deductions from the amounts paid u/s. 195 - Double Taxation Avoidance Agreement (between India and United Kingdom) - Art. 5 Double Taxation Avoidance Agreement (between India and United Kingdom): Art. 5 - Permanent Establishment - What constitutes Permanent Establishment - Explained. H 152FORMULA ONE WORLD CHAMPIONSHIP LTD. v. COMMISSIONER OF INCOME TAX 153 Art. 5 - Permanent Establishment - Conditions to be ··satisfied - Held: Twin conditions to be satisfied are existence of a fixed place of business; and through that place business of an enterprise is wholly or partly carried out. A Dismissing the appeals by FOWC and Jaypee and disposing of the appeal by the Revenue, the Court |
Judge | Hon'ble Mr. Justice Arjan Kumar Sikri |
Neutral Citation | 2017 INSC 389 |
Petitioner | Formula One World Championship Ltd. |
Respondent | Comissioner Of Income Tax, International Taxation-3, Delhi & Anr. |
SCR | [2017] 2 S.C.R. 152 |
Judgement Date | 2017-04-24 |
Case Number | 3849 |
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