https://www.taxtmi.com/caselaws?id=180542 Business connection and a permanent establishment in India were accepted, but taxability depended only on income attributable to Indian operations. Applying the functions-assets-risks attribution principle and the coordinate bench approach in the Galileo line of cases, the Tribunal held that the Indian marketing and booking support was only a limited part of the overall reservation system. Because the assessee had already paid 25% of gross receipts to the Indian subsidiary, exceeding the comparable 15% attribution benchmark, no further income was attributable to India and nothing more was taxable there. en-us Fri, 20 Aug 2010 00:00:00 +0530 Tue, 29 Mar 2016 13:08:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=180542 Business connection and a permanent establishment in India were accepted, but taxability depended only on income attributable to Indian operations. Applying the functions-assets-risks attribution principle and the coordinate bench approach in the Galileo line of cases, the Tribunal held that the Indian marketing and booking support was only a limited part of the overall reservation system. Because the assessee had already paid 25% of gross receipts to the Indian subsidiary, exceeding the comparable 15% attribution benchmark, no further income was attributable to India and nothing more was taxable there. Case-Laws Income Tax Fri, 20 Aug 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=180542