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of <h1>Court Allows 460-Day Delay in Appeals on Profit Attribution, Closing Case with No Substantial Legal Questions Found.</h1> <h3>The Commissioner of Income Tax – International Taxation -3 Versus Travelport Global Distribution System B.V. (Earlier Known As Galileo Nederlands BV)</h3> The Commissioner of Income Tax – International Taxation -3 Versus Travelport Global Distribution System B.V. (Earlier Known As Galileo Nederlands BV) - TMI Issues involved: Applications for condonation of delay in re-filing appeals, Appeals concerning different Assessment Years, Merits of the case based on Supreme Court decision.Condonaion of Delay: The appellant/revenue filed applications seeking condonation of a 460-day delay in re-filing the appeals. The court, intending to decide the appeals on merits, inclined to condone the delay and ordered accordingly, disposing of the applications.Assessment Years: The appeals pertained to various Assessment Years - 2007-08, 2008-09, 2009-10, 2010-11, 2011-12, 2012-13, and 2014-15. The appellant/revenue aimed to challenge the common order of the Income Tax Appellate Tribunal dated 13.10.2021.Merits of the Case: The key issue in the appeals was whether 15 percent of the profits from Indian operations could be attributed to the respondent/assessee, a matter previously upheld by the Supreme Court in a related case. The court found no substantial question of law for consideration based on the previous decisions and closed the appeals accordingly. The order was to be dispatched to the respondent/assessee via all modes, including e-mail.
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