The article discusses the recent judgement of Bombay High Court which reaffirms the primacy of treaty interpretation based on the nature of income, rather than the mechanism or incidence of collection under municipal law, and has far-reaching implications for pending disputes under the erstwhile DDT regime.

The ruling excludes vacation and business development days from service PE calculations and confirms virtual services from abroad don’t count, potentially reshaping compliance for multinationals

On 23 December 2025, the NCLAT delivered a Judgement on the issue involving Section 59 of the Companies Act, 2013 (‘Act’) upholding the Order passed by the NCLT, Hyderabad.

The article discusses the question as to whether Customs or GST Department has jurisdiction and to what extent, if IGST is declared to be a levy under the CTA or the IGST Act, respectively.

While ensuring lawful licensing is a foundational obligation and even unintentional misuse must be course-corrected, at the same time, enforcement practices should reflect the highest of ethical and legal standards.