Income Tax, HC Delhi Judgement Dated 14/01/2026 – Virtual Service PE not valid ground to deny Nil Withholding Certificate 

Case of Ernst and Young LLP vs ACIT, HC Delhi Judgement Dated 14th January 2026. HC ruled that the concept of a “virtual service PE” is not contemplated by the Income Tax Act or the relevant Double Taxation Avoidance Agreements (DTAA). The court held that without physical presence or rendering services within India, a Virtual Service PE cannot be established, overturning tax demands on professional service fees. 

(Link: HC Delhi Judgement Dated 14/01/2026)

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