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    <title>2023 (6) TMI 378 - ITAT DELHI</title>
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    <description>The Tribunal upheld the finding that the assessee carried on business through a business connection and permanent establishment in India. It also restricted attribution of income from the CRS business to 15% of gross booking fees, following earlier rulings and noting that India-related expenses exceeded the attributable revenue, leaving no further taxable income in India. The disallowance of royalty, licence fee and similar expenses was confined to 30%, with assessment to be recomputed accordingly. Interest under section 234B was treated as consequential and left to be worked out in accordance with law.</description>
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      <description>The Tribunal upheld the finding that the assessee carried on business through a business connection and permanent establishment in India. It also restricted attribution of income from the CRS business to 15% of gross booking fees, following earlier rulings and noting that India-related expenses exceeded the attributable revenue, leaving no further taxable income in India. The disallowance of royalty, licence fee and similar expenses was confined to 30%, with assessment to be recomputed accordingly. Interest under section 234B was treated as consequential and left to be worked out in accordance with law.</description>
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