More than 15% of revenue generated from India can’t be attributed to Permanent Establishment: ITAT

Amadeus IT Group SA C/O. Vs ACIT (ITAT Delhi)

Conclusion: The ITAT by relying upon the Judgment of co-ordinate Bench, wherein co-ordinate Bench followed the Judgment of Jurisdictional High Court have observed that 15% of the revenue relating to bookings made from India being attributable to the taxpayer’s PE in India after considering the nature and extent of activities in India and abroad and assets employed & risk assumed.

Facts:

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