Held, dismissing the appeals and cross-objections, that there was no reason to interfere with the reasoned order of the Commissioner (Appeals). The receipts of the assessee for the subsequent assessment years 2015-16, 2016-17 and 2017-18, had also been taxed at 10 per cent. which had been followed in terms of the decision of the Commissioner (Appeals) for the year under consideration. The order of the Commissioner (Appeals) was affirmed.(AY.2013-14, 2014-15)
Asst. CIT (IT) v. Sabre Decision Technologies International LLC (2023)102 ITR 610 (Delhi) (Trib)
S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Permanent Establishment — Providing online decision support applications for Airline companies in India-Not business income — Taxable only on gross basis under Section 115A at 10 Per Cent. — Expenses not allowable —DTAA -India -USA.[S. 9(1)(i), 44DA,