Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
