PE case lawIndian tribunal overrules revenue department ruling on the existence of a PE for a computer reservation system providerOn 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 various airlines, wherein through its computer reservation system (CRS), it agreed to facilitate ticket bookings and provide related services. It also entered into...