CRS installed via computers at premises of subscribers is fixed place of business in India

Travelport Global Distribution system BV Vs ACIT (ITAT Delhi)

ITAT Delhi held that CRS, which was the source of revenue, was partially existent in the machines namely various computers installed at the premises of the subscribers. As assessee exercised complete control over the computers installed at premises of the subscribers. This amounted to a fixed place of business for carrying on the business of the enterprise in India.

Facts- The Assessee is a company incorporated

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