Accrual of income in India - PE in India or not? - Agency PE - ...

Sabre GLBL Inc. not liable for taxes in India post-2005; no Permanent Establishment under revised business model.

February 13, 2024

Case Laws Income Tax AT

Accrual of income in India - PE in India or not? - Agency PE - whether assessee has a business connection in India under Section 9(1)? - The ITAT Delhi ruled in favor of the assessee, finding that the business model post-2005 did not create a Permanent Establishment (PE) or an Agency PE in India for Sabre GLBL Inc., as the operations and agreements post-2005 significantly differed from the earlier model. The Tribunal differentiated the current business operations from those evaluated in the case of Galileo International Inc., where a PE was established due to the presence of an intermediary.

View Source

← Previous Next →

Accrual of income in India - PE in India or not? - Agency PE - ...

Sabre GLBL Inc. not liable for taxes in India post-2005; no Permanent Establishment under revised business model.

February 13, 2024

Case Laws Income Tax AT

You may also like:

Income accrued in India - permanent establishment (PE) - Withholding of tax in India - vessel engaged in seismic survey at high sea - The sum paid by the applicant to...

TDS u/s 195 - Disallowance u/s 40(a)(i) - the said income in the hands of non-resident has to be considered in the light of the provisions of DTAA between India and the...

TDS u/s 195 not deducted on payment to Everest Global Inc. for software training services as source of income located outside India and payment made for services outside...

Fees for technical service was liable to tax in India under section 44BB of the Act only if the appellant had Permanent Establishment ("PE") in India in the relevant...

Taxability of interest on income tax refund received - PE in India or not? - whether shall be taxable as business income under Article 7 of India-France DTAA as against...

Income accrued in India - Permanent Establishment (PE) - the distribution income earned by the assessee cannot be taxed in India because Taj India does not constitute an...

Appellant not liable to pay tax on outbound tours irrespective of service recipient's location as per Rule 3(2) of Export of Service Rules, 2005 and Notification No....

Existence of Fixed Place Permanent Establishment (“Fixed Place PE”) and Supervisory Permanent Establishment (“Supervisory PE”) - India-Japan DTAA - Merely providing...

Income taxable in India or not - Taxation of Technical Collaboration Fees @ 10% u/s. 9(1)(vii) r.w.s 115A(1)(b) - The Appellate Tribunal considered the arguments...

The High Court considered the validity of reassessment proceedings regarding the taxability of income without Permanent Establishment in India under India-Japan DTAA,...

Income accrued in India - interest income on loans in the form of suppliers credit given to Indian parties - As alleged that the Indian parties from whom the assessee...

Permanent Establishment under Article 5 of the DTAA between India and U.S.A - Whether Appellant has a Permanent Establishment ('PE') in India under Article 5 of the DTAA...

The appellant provided steamer agent and cargo handling agency services, which involved segregation, internal shifting of timber logs, and sending progress reports to...

Income taxable in India - PE in India - Once we hold that in the light of the present legal position, existence of dependent agency permanent establishment in wholly tax...

Payment received from resellers in India for acquisition of computer software - Assessee who is a non resident does not have a permanent establishment and therefore...

Quick Updates: