Revenue Generated from Bookings Made within India Attributable to PE, Hence Taxable in India

DDIT Vs Travelport L.P. USA  (ITAT Delhi) The issue under consideration is whether revenue generated from the bookings made within India is the revenue attributable to the PE of the assessee is taxable in India? ITAT states that the major functioning, i.e., collecting data bases with various airlines, hotels etc. and entering or feeding them into the computer took place outside India. It was in the computer in Denver, USA that various processed data with regard to schedule of flights timing, pricing, availability, meal preference, special facilities etc. was stored and process undertaken. The...