https://www.taxtmi.com/caselaws?id=403866 ITAT Delhi held that, on materially identical facts and the same business model as earlier years, a fixed place permanent establishment and a dependent agent permanent establishment in India existed under the Indo-Spain DTAA. For profit attribution, it followed prior orders and jurisdictional High Court approval to restrict attribution to 15% of India-linked booking revenues, while deleting disallowances of distribution, development, marketing, data processing and related expenses. It further held that CRS booking fees and Altea system receipts were business income, not royalty, because no treaty right to use a process or equipment was shown. Interest under section 234B was held not leviable in the circumstances. en-us Fri, 29 Jan 2021 00:00:00 +0530 Tue, 09 Feb 2021 10:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=403866 ITAT Delhi held that, on materially identical facts and the same business model as earlier years, a fixed place permanent establishment and a dependent agent permanent establishment in India existed under the Indo-Spain DTAA. For profit attribution, it followed prior orders and jurisdictional High Court approval to restrict attribution to 15% of India-linked booking revenues, while deleting disallowances of distribution, development, marketing, data processing and related expenses. It further held that CRS booking fees and Altea system receipts were business income, not royalty, because no treaty right to use a process or equipment was shown. Interest under section 234B was held not leviable in the circumstances. Case-Laws Income Tax Fri, 29 Jan 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=403866