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2023 (12) TMI 772 - HC - Income TaxAttribution of profits earned from Indian operations - whether the view taken by CIT(A) that 15 percent of the profits earned from Indian operations could be attributed to the respondent/assessee was sustainable? - HELD THAT:- The coordinate bench in AY 2006-07 while dealing with [2021 (10) TMI 1004 - ITAT DELHI] has sustained the said conclusion and gone on to hold that no substantial question of law arose for its consideration. It is this decision which was affirmed by the Supreme Court Travelport L.P. USA [2023 (7) TMI 700 - SC ORDER] considered and held against the Revenue.
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