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Treaty between India and the United States – Indian decision on existence of PE re computerized reservation system

|Treaty Development|India-United States
India-United States

The Indian Income Tax Appellate Tribunal (ITAT) delivered a ruling dated 30 November 2007 in the case of Galileo International Inc. v. Deputy Commissioner of Income Tax on whether a person engaged in the business of providing Computerized Reservation System (CRS) services had, (i) any source of income in India, (ii) a permanent establishment (PE) in India, and (iii) if the PE was li…

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