ITAT Rejects Virtual Service PE Theory, Holds LinkedIn Profile Not Conclusive for PE Determination Case Details Case Reference ITA No. 1890/Del/2025/ AY 2022-23/ ITAT Delhi Bench “A” Appellant IMAX Theatre Services Ltd, Canada Respondent ACIT, Circle 2(1)(1), International Taxation, New Delhi Date of Order 13-May-26 Outcome Appeal ALLOWED: Addition of Rs 76,25,731 deleted in full…
ITAT Delhi Rejects Permanent Establishment Allegation Based Solely on LinkedIn Evidence The ITAT Delhi has held in favour of IMAX Theatre Services Limited in a dispute related to the existence of a Permanent Establishment (PE) in India for the Assessment Year 2022-23. The assessee, IMAX Theatre Services Limited, is a tax resident of Canada and…
Delhi ITAT Denies Profit Attribution Without Existence of Permanent Establishment The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) on 13 May 2026 held that remote access provided for maintenance and troubleshooting of IMAX theatre systems cannot by itself constitute a Fixed Place Permanent Establishment (PE) or a virtual Service PE in India under…
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