Where assessee has dependent agent & fixed place of business in India he is deemed to be PE as per Article 5 (1) of Indo US tax treaty

Brief of the case:

In the case of Travelport LP USA Vs. DDIT Delhi Bench of ITAT observed that assessee has a dependent agent in form of distributor in India and held that assessee has a business connection in India u/s 9(1) (i) of the act and its income is deemed to accrue or arise in India.

Facts of the case:

• Assessee is a Limited partnership based in the State of Delaware, USA, having its principal place of business at Georgia. It is engaged in the business of providing

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