Assessee is  a tax resident of US and carried on business of providing information, reservations, transaction processing and related services for airlines, travel agencies and other travel related entities by utilizing a Computerized Reservation System (CRS). Assessing Officer held that assessee had a business connection in India under section 9(1)(i) and PE in terms of article 5(4)(a) of Indo-US Treaty and, accordingly, assessee’s income generated in India was chargeable to tax under section 9(1)(i) of the Act.   Tribunal held that computers at desk of travel agent in India were merely connected to extent that it could perform a booking function but were not capable of processing data of all airlines together at one place. No assets were deployed to India. Tribunal  held  that major part of business activities were carried out outside India in USA and only limited activities were attributable to India, 15 per cent of revenue was enough to attribute towards activities done in India.. No substantial question of law. (AY. 2006-07)