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2023 (8) TMI 164 - SCH - Income TaxIncome taxable in India - Income attributable to the operations carried out in India - attribution of only 15% of the revenue as income accruing /arising in India within the meaning of Section 9(1)(i) read with Article 7 of the Treaty - HELD THAT:- These appeals could be disposed of by following the order passed by this Court in TRAVELPORT INC. [2023 (5) TMI 227 - SUPREME COURT] As respondent-Jet Lite (India) Limited is in Liquidation and therefore the said fact may be borne in mind while passing orders in these cases. The impugned order(s) of the High Court do not call for interference. Insofar as the second issue, namely the question of permanent establishment is concerned, we are not going into the same, as we have concurred with the High Court on the first issue. The petitions filed by the petitioner/department(s) of income tax are dismissed. Pending application(s), if any, shall stand disposed of
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