Commission income earned by Booking.com not taxable in India

Booking.com B.V. Vs ACIT (ITAT Delhi)

Booking.com platform earning of commission income is not taxable in India since AO has failed to discharge the onus of establishing assessee having fixed place PE in India. Accordingly, final assessment order is liable to be set aside.

Facts- Assessee, Booking.Com B.V., didn’t file return of income. The case of the assessee was picked by risk management strategy of insight for non-filing of income tax return. On completion of proceedings, ld. AO vide order dated 15.01.2025 made addition of Rs.3,96,09,81,782/- bein

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