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Formula One Championship

Supreme Court of India·2017·ITR
Facts

F1 Championship's circuit access at Buddh International Circuit in India.

Issue

Whether F1 had a Permanent Establishment in India under India-UK DTAA?

Held

Yes. The Buddh circuit constituted a fixed place of business at FOWC's disposal during the F1 weekend, satisfying the PE test.

Ratio

PE need not be permanent in time; duration + control over the place is sufficient.

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