Income of ‘Sabre Asia Pacific’ from computerized Air ticket reservation taxable in India

Sabre Asia Pacific Pte Ltd Vs ACIT (ITAT Mumbai)

The first issue that needs to be decided is whether the assessee has a permanent establishment in India or not? This is challenged as per ground 2 of the appeal. We find that this issue is squarely covered against the assessee by the decision of the co-ordinate bench in assessee’s own case from assessment years 1999-2000 to 20 14-15. The co-ordinate benches have originally followed the decision in the case of the assessee for assessment year 1999-2000 in ABACUS INTERNATIONAL PTE LTD. VERSUS THE ASST. DI

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