DIRECTOR OF INCOME TAX -II NEW DELHI vs M/S SAMSUNG HEAVY INDUSTRIES CO. LTD

The Supreme Court addressed the taxability of income related to a permanent establishment in India under the Double Taxation Avoidance Agreement (DTAA) with South Korea. The court examined the nature of the Project Office established by Samsung Heavy Industries in Mumbai and its implications for tax obligations. Ultimately, the court ruled that the income attributable to the permanent establishment was taxable in India, affirming the Department's stance on the matter.