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2024 (1) TMI 363 - HC - Income TaxAccrual of Income in India - PE in India - attribution rate of revenue for the Indian operations of the Permanent Establishment - 75 percent of the gross profits earned from Indian operations, attributed to the respondent/assessee sustained by DRP - HELD THAT:- Tribunal partly allowed the appeal of the respondent/assessee by following its own decision for AYs 2007-08 to 2014-15, thereby directing the Assessing Officer to adopt the attribution rate of revenue for the Indian operations of the Permanent Establishment at 15 percent of gross booking fees for the AY in issue, i.e., AY 2015-16. The coordinate bench in AY 2006-07, while dealing with [2022 (9) TMI 311 - DELHI HIGH COURT], 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 with the dismissal of the SLP, as noted in Travelport L.P. USA [2023 (7) TMI 700 - SC ORDER] Given this position, we are of the opinion that no substantial question of law arises for our consideration.
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