Assessee, a Singapore based company, was engaged in business of promotion, development, marketing and maintenance of Computerized Reservation System (CRS). Primary business of assessee was to make reservations for and on behalf of participating airlines using CRS. Assessee licensed rights to market CRS in India to its wholly owned subsidiary company ADSIL as its National Market company in India-Assessee claimed that it did not have any PE in India, and, hence, fees received from providing airline reservations services to various airlines was not taxable in India.  Assessing Officer held that ADSIL was functioning as a controlled subsidiary of assessee and was exclusively performing marketing and distribution of CRS for assessee and also found that ADSIL was securing business for assessee by entering into subscription agreements with travel agents and as said activity was habitually, wholly and exclusively performed for assessee, ADSIL could be regarded as agency PE of assessee in India   The Tribunal up held the order of the Assessing Officer. Followed order of Tribunal for earlier year.  (AY. 2013-14)