https://www.taxtmi.com/caselaws?id=63779 The Central Reservation System (CRS) ownership dispute was resolved in favor of the assessee's subsidiary, not the assessee, from April 1, 1994. The income earned through the AXESS CRS was found not taxable in India as no income accrued to the assessee. The Double Taxation Avoidance Agreement (DTAA) provisions were upheld, preventing taxation of the income. The assessment of income as royalty was deemed irrelevant by the ITAT, emphasizing that no income could accrue to the assessee. The misrepresentation allegations against the assessee were dismissed, with the ITAT affirming that no income was assessable in India. The Department's appeal was ultimately dismissed. en-us Wed, 24 Nov 2004 00:00:00 +0530 Tue, 01 Feb 2011 17:46:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=63779 The Central Reservation System (CRS) ownership dispute was resolved in favor of the assessee's subsidiary, not the assessee, from April 1, 1994. The income earned through the AXESS CRS was found not taxable in India as no income accrued to the assessee. The Double Taxation Avoidance Agreement (DTAA) provisions were upheld, preventing taxation of the income. The assessment of income as royalty was deemed irrelevant by the ITAT, emphasizing that no income could accrue to the assessee. The misrepresentation allegations against the assessee were dismissed, with the ITAT affirming that no income was assessable in India. The Department's appeal was ultimately dismissed. Case-Laws Income Tax Wed, 24 Nov 2004 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=63779