PE case law
Indian tribunal overrules revenue department ruling on the existence of a PE for a computer reservation system provider
On 9 February 2024, the Delhi Bench of the Income Tax Appellate Tribunal (ITAT) issued decision No. 6731/Del/2015, addressing the existence of a permanent establishment (PE) in India for a company in the United States (US). The primary business activity of this US company in India was facilitating airline and hotel bookings.
The US company entered into agreements with …