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ITAT held that the assessee, a travel agent using Computerized Reservation System (CRS) for booking air tickets, is not an e-commerce operator under Section 194O. The Tribunal determined that the assessee merely had access to the Galileo system owned by Interglobe Technology Quotient Pvt. Ltd. (ITQPL) for obtaining travel information and making bookings, without any ownership rights or operational control over the platform. The subscriber agreement explicitly restricted the assessee from modifying the software and confirmed ITQPL's ownership. Consequently, the assessee was not liable to deduct TDS under Section 194O and cannot be considered "an assessee in default." Revenue's appeal dismissed.
ITAT held that the assessee, a travel agent using Computerized Reservation System (CRS) for booking air tickets, is not an e-commerce operator under Section 194O. The Tribunal determined that the assessee merely had access to the Galileo system owned by Interglobe Technology Quotient Pvt. Ltd. (ITQPL) for obtaining travel information and making bookings, without any ownership rights or operational control over the platform. The subscriber agreement explicitly restricted the assessee from modifying the software and confirmed ITQPL's ownership. Consequently, the assessee was not liable to deduct TDS under Section 194O and cannot be considered "an assessee in default." Revenue's appeal dismissed.
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