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 information, reservations, transaction processing and related services for airlines, Travel agencies and other travel-related entities.

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