Operational control over hotels in India creates Hyatt UAE’s ‘permanent establishment’ in India

In a landmark ruling on a foreign entity’s taxable presence in India, the Supreme Court in Hyatt International Southwest Asia Ltd. v Additional Director of Income-tax, 2025 INSC 891 held that the existence of sustained, pervasive, and enforceable control over a hotel’s strategic, operational, and financial affairs is sufficient to constitute a ‘Permanent Establishment’ (PE) of a foreign enterprise in India.