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McDonald’s Corporation v. Assistant Commissioner of Income Tax

Case No: ITA No.- 211/Del/2017 & two other appeals
Court: Income Tax Appellate Tribunal, Delhi Bench
Bench: Delhi Bench
Date: 2/13/2026

Parties Involved

appellantMcDonald’s Corporation
respondentAssistant Commissioner of Income Tax

Facts Summary

The assessee, McDonald’s Corporation, filed appeals against assessment orders for AYs 2012-13, 2013-14, and 2014-15. The appeals were filed following directions from the Hon’ble Dispute Resolution Panel (DRP). The assessee later sought withdrawal of these appeals due to a resolution reached under the Mutual Agreement Procedure (MAP) between the Competent Authorities of India and the United States.

Decision in favour of

Revenue

Legal Issues

  • 1. Alleged Permanent Establishment (PE) of the Appellant in India
  • 2. Adjustment on royalty income for AY 2012-13

Precedents Relied Upon

Judgment Outcome

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