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TMI Blog2022 (9) TMI 311X X X X Extracts X X X X X X X X Extracts X X X X ..... RT ] - HELD THAT:- ITAT and CIT(A) have held that out of several activities, the activities of Calleo Distribution Technologies Private Limited in India were only in respect of generating request and receiving end-result of the process. In other words, the computers at the desk of the travel agent in India were merely connected to the extent that they could perform a booking function but were not ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... N'BLE MR. JUSTICE MANMOHAN AND HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA Appellant Through: Mr. Ruchir Bhatia, Senior Standing Counsel for the Revenue along with Mr. Shlok Chandra, Junior Standing Counsel for Revenue. Respondent Through: None J U D G M E N T MANMOHAN, J (Oral): 1. Present Income Tax Appeal has been filed challenging the order dated 9th Nove ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... scenario has drastically changed after the Assessment Year 2007-08 as the orders passed for the subsequent Assessment years have extensively dealt with the facts and law. 5. A perusal of the paper book reveals that the ITAT has held that since no guidelines are available as to how much income of the Assessee-Respondent be reasonably attributable to India, the same has to be determined on the ba ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... el I Distribution S.A. v. DCIT 113 TTJ 767. 8. In the impugned order, the ITAT held that the present case was similar to that of Galileo International (Supra) and that the CIT(A) rightly attributed 15% of the revenue to the Respondent s PE in India. In fact, the Appellant has not brought on record anything which differentiates the facts of this case with that of Galileo International (Supra). ..... X X X X Extracts X X X X X X X X Extracts X X X X
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