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Since assessee Dutch Company was engaged in providing travel industry services of Computerised Reservation System and its Indian Distributor merely gave connection to Indian travel agents for booking and major functioning of collecting and data analysis/development took place in USA, attribution of 15% of assessee's profit to India was just and proper - Assistant Director of Income tax.

SUPREME COURT OF INDIA

 

SPECIAL LEAVE TO APPEAL (C) NO. 128 OF 2015

 

Assistant Director of Income-tax........................................................................Appellant.
v.
Galileo Nederland BV ...........................................................................Respondent

 

ANIL R. DAVE AND SHIVA KIRTI SINGH, JJ.

 
Date :JANUARY  12, 2015
 
Appearances

 Tushar Mehta, Rupesh Kumar, Giriraj Subramaniam, Ms. Gargi Khanna, and Mrs. Anil Katiyar, Advs. for the Petitioner.


Section 9 of the Income Tax Act, 1961 — Income — Income deemed to accrue or arise in India — Since assessee Dutch Company was engaged in providing travel industry services of Computerised Reservation System and its Indian Distributor merely gave connection to Indian travel agents for booking and major functioning of collecting and data analysis/development took place in USA, attribution of 15% of assessee's profit to India was just and proper — Assistant Director of Income tax.


ORDER


1. Delay condoned.

2. Leave granted.

 

[2015] 230 TAXMAN 361 (SC)

 
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