HC upheld ITAT order attributing 15% of revenue to PE in India of Travelport L.P. USA

CIT-International Taxation Vs Travelport L.P. USA (Delhi High Court) Learned counsel for the Appellant-Revenue states that the ITAT has erred in holding that only 15% of the revenue is attributable to the assessee’s PE in India by mechanically applying the ratio of the judgment of DIT vs. Galileo International Inc., (2009) 180 Taxman 357 (Delhi) without appreciating that the facts of the instant case are different. A perusal of the paper book reveals that the ITAT has held that since no guidelines are available as to how much income of the Assessee-Respondent be reasonably attributable t...