AZB & Partners is one of India's premier law firms with 500+ lawyers and offices across the country. The firm was founded in 2004 with a clear purpose to provide reliable, practical and full–service advice to clients, across all sectors. Having grown steadily since its inception, AZB & Partners now has offices across Mumbai, Delhi, Bangalore, Pune and Chennai. We are recognized by most international publications for our legal expertise.
AZB & Partners achieved a significant victory for LG Electronics Inc., Korea, before the Income Tax Appellate Tribunal in Delhi, addressing whether employee secondment from a foreign entity to its Indian counterpart creates a Permanent Establishment in In
India
AZB & Partners successfully represented LG Electronics Inc.,
Korea, in proceedings before the Income Tax Appellate Tribunal,
Delhi, leading to the recent decision by the Tribunal, which
clarifies that the secondment of employees by a foreign entity to
its Indian counterpart does not, by itself, result in the formation
of a Permanent Establishment (PE) of the foreign entity in
India.
The judgement decided in favour of LG Electronics Inc, Korea,
brings an end to a longstanding dispute and serves as an important
judgement on an issue that remains one of the most contentious
areas in international tax law in India today.
The disputes team comprised of our Partner Ankul Goyal and
Associate Adwiteya Grover.
Originally published 8 September, 2026
Contributor
AZB & Partners is one of India's premier law firms with 500+ lawyers and offices across the country. The firm was founded in 2004 with a clear purpose to provide reliable, practical and full–service advice to clients, across all sectors. Having grown steadily since its inception, AZB & Partners now has offices across Mumbai, Delhi, Bangalore, Pune and Chennai. We are recognized by most international publications for our legal expertise.
