As per the case facts several appeals arose from a common High Court judgment regarding Income Tax The High Court had made a decision concerning income tax for multiple assessment ... years The question arose whether specific transactions constitute a business connection under Section i of the relevant act and if so whether there was a permanent establishment as defined by international agreements Finally the Supreme Court determined that the concept of permanent establishment is crucial for tax purposes and involves a fixed place of business They clarified that a place must involve a certain amount of physical space and the use of land is strongly linked to the taxing powers of a State The Court also discussed whether certain activities could be considered auxiliary noting that the taxing rights of the source State over foreign income are limited by double taxation avoidance agreements The court emphasized that activities merely preparing for or supporting the core business are unlikely to create a permanent establishment