Tribunal held that since major part of business activities were carried out outside India in U.S.A and only limited activities were attributable to India, 15 per cent of revenue was enough to attribute towards activities done in India. (AY. 2006 07 to 2010-11)
DIT v. Travelport L.P. USA. (2021) 187 ITD 572 (Delhi)(Trib.)
S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Providing information, reservations, transaction processing and related services to airlines, travel agencies and other travel related entities by utilizing a Computerized Reservation System (CRS)-15% of profit was attributable to India-DTAA-India-USA. [Art. 5]