2023 (8) TMI 166 - SCH - Income Tax

Income taxable in India - Income attributable to the operations carried out in India - attribution of only 15% of the revenue as income accruing /arising in India - HELD THAT - Learned counsel appearing for the petitioner/Revenue(s) as well as learned counsel for the respondent(s) jointly submit that these petitions could be dismissed in terms of the order of Director of Income Tax, New Delhi vs. Travelport Inc. 2023 (5) TMI 227 - SUPREME COURT We are of the view that the impugned order(s) of the High Court do not call for interference. Insofar as the second issue, namely the question of permanent establishment is concerned, we are not going into the same, as we have concurred with the High Court on the first issue.

Summary

The Supreme Court dismissed special leave petitions filed by the petitioner/department(s) of income tax, following the order in C.A. Nos.6511-6518/2010. The Court did not interfere with the High Court's decision regarding the question of permanent establishment. Pending applications were disposed of.