India

Vaish Associates Advocates | English | AcademicThink | Dec. 12, 2025 | UndeterminedLegal Exposure

The Delhi High Court, in the case of CIT v. Clifford Chance Pte. Ltd. (ITA No. 353/2025 and 354/2025), ruled that the tax authorities cannot apply the concept of Virtual Service Permanent Establishment (PE) in the absence of a specific clause in the India-Singapore Double Taxation Avoidance Agreement (DTAA). This decision prevents taxing the profits of a non-resident taxpayer in India based on a Virtual Service PE notion not recognized by the treaty.

Additionally, the Court clarified the computation of days spent in India for constituting a Service PE under Article 5(6)(a) of the DTAA. It held that days during which the taxpayer’s employees were on vacation or engaged in business development activities should be excluded from the count. This interpretation impacts how the duration threshold for Service PE is calculated under the treaty.

Hindu Business Line | English | News | Dec. 12, 2025 | Regulation

Mexico’s Senate has approved tariff increases of up to 50% on imports from China and several Asian countries, including India, South Korea, Thailand, and Indonesia, starting in 2026. This move aims to protect and promote domestic manufacturing amid opposition from business groups and foreign governments.

The tariff hikes will mainly range up to 35% and will affect a variety of goods such as automobiles, auto parts, textiles, clothing, plastics, and steel. These increases will apply to imports from countries that do not have existing trade agreements with Mexico. The legislation had already been passed by the lower house before receiving Senate approval.

The Hindu | English | News | Dec. 12, 2025 | Regulation

The Commission for Air Quality Management (CAQM) informed the Supreme Court that over 63 lakh end-of-life vehicles continue to operate on the roads of the national capital, significantly contributing to air pollution. CAQM attributed this to inadequate coercive action by authorities and a Supreme Court order from August 12 that lifted restrictions on these vehicles. While the number of vehicles impounded in Delhi rose to 35,558 by June 2025, progress in removing old petrol and diesel vehicles from the National Capital Region (NCR) remains unsatisfactory.

The Commission highlighted that many vehicles with Bharat Stage (BS) emission standards II, III, and I, which exceed 15 to 24 years in age, are still on the roads despite their high pollution potential. CAQM emphasized that vehicle fitness is tied to emissions aligned with BS standards, and restricting vehicles with poor emission standards is crucial, especially during winter when pollution dispersion is poor in Delhi-NCR. Approximately 93% of vehicles in the NCR are light motor vehicles and two-wheelers, making their regulation vital to air quality.

CAQM has directed that, starting November 1, 2026, no buses other than CNG, electric, or BS-VI diesel buses (excluding those registered in Delhi) should enter the capital. Additionally, state governments in Delhi and the NCR have been instructed to urge motor vehicle aggregators, delivery services, and e-commerce companies to switch to cleaner vehicles promptly. The Commission also mandated a phased but time-bound phaseout of diesel auto-rickshaws across the NCR by 2026.