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2022 (9) TMI 311 - DELHI HIGH COURTIncome attributable to the assessee's PE in India - Deployment of assets in India - ITAT holding that only 15% of the revenue is attributable to the assessee's PE in India applying the ratio of Galileo International Inc [2009 (2) TMI 497 - DELHI HIGH COURT] - HELD THAT:- ITAT and CIT(A) have held that out of several activities, the activities of Calleo Distribution Technologies Private Limited in India were only in respect of generating request and receiving end-result of the process. In other words, the computers at the desk of the travel agent in India were merely connected to the extent that they could perform a booking function but were not capable of processing the data of all the airlines together at once place. The ITAT also held that the Assessee has not deployed any assets in India. ITAT in the present case not only relied upon the judgment of this Court in Galileo International (Supra) but also relied on the judgment of its Coordinate Bench in Amadeus Global Travel I Distribution S.A. [2007 (11) TMI 330 - ITAT DELHI-B] ITAT held that the present case was similar to that of Galileo International (Supra) and that the CIT(A) rightly attributed 15% of the revenue to the Respondent’s PE in India. In fact, the Appellant has not brought on record anything which differentiates the facts of this case with that of Galileo International (Supra). No substantial question of law.
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