https://www.taxtmi.com/caselaws?id=274647 Where a composite cross-border reservation business operated with the host computer outside India and limited marketing/support functions in India, taxability was confined to income fairly attributable to Indian operations on a functions, assets and risks basis. The Tribunal applied the principle that only the Indian slice of a larger business can be taxed where a business connection or permanent establishment is assumed. It attributed 15% of gross receipts to India, but held that no further income was taxable because the commission paid for Indian services had already absorbed that attributable amount. en-us Sat, 28 Aug 2010 00:00:00 +0530 Mon, 27 Aug 2018 11:59:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=274647 Where a composite cross-border reservation business operated with the host computer outside India and limited marketing/support functions in India, taxability was confined to income fairly attributable to Indian operations on a functions, assets and risks basis. The Tribunal applied the principle that only the Indian slice of a larger business can be taxed where a business connection or permanent establishment is assumed. It attributed 15% of gross receipts to India, but held that no further income was taxable because the commission paid for Indian services had already absorbed that attributable amount. Case-Laws Income Tax Sat, 28 Aug 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=274647