2024 (1) TMI 363

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..... ough: Mr Ruchir Bhatia, Sr. Standing Counsel For the Respondent Through: None. RAJIV SHAKDHER, J. (ORAL): CM APPL. 64099/2023 in ITA 748/2023 [Application filed on behalf of the appellant seeking condonation of delay of 220 days in re-filing the appeal] 1. This is an application filed by the appellant/revenue, seeking condonation of delay in re-filing the appeal. 2. According to the appel .....

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..... awn our attention to the following order passed by the Supreme Court in the case of Commissioner of Incometax (International Taxation) v. Travelport L.P. USA, [2023] 153 taxmann.com 176 (SC). Since the order of the Supreme Court refers to a judgment of this court, the order is extracted hereafter: "1. Delay of 146 days is condoned. 2. Learned Additional Solicitor General appearing for the pet .....

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..... /assessee by following its own decision for AYs 2007-08 to 2014-15, thereby directing the Assessing Officer to adopt the attribution rate of revenue for the Indian operations of the Permanent Establishment at 15 percent of gross booking fees for the AY in issue, i.e., AY 2015-16. 8.1 The coordinate bench in AY 2006-07, while dealing with ITA 301/2022, has sustained the said conclusion and gone on .....

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