What is Amadeus Global Travel Distribution S.A v. DCIT authority for?

Where the expenses paid to a related entity were allowed as a deduction in computing the income of the taxpayer, the income attributable to a Permanent Establishment (PE) in India, if less than the remuneration paid, should be calculated accordingly, following Article 7 of the Double Taxation Avoidance Agreement (DTAA).

How many judgments cite Amadeus Global Travel Distribution S.A v. DCIT?

29 judgments on BharatTax cite Amadeus Global Travel Distribution S.A v. DCIT (113 TTJ 767), spanning 2019 to 2024.

Which sections of the Income Tax Act does Amadeus Global Travel Distribution S.A v. DCIT come up under?

It is most often cited in judgments turning on Section 1961, Section 143(2) of the Income Tax Act, Section 143(3) of the Income Tax Act, Section 144C(13) of the Income Tax Act, Section 1961: Section 143(2), Section 1961: Section 143(3).

Amadeus Global Travel Distribution S.A v. DCIT (113 TTJ 767)

DCIT, CIRCLE 3(1) (1), INTERNATIONAL TAXATION, NEW DELHI vs. RICARDO UK LTD, NEW DELHI

In the result, the appeals are dismissed

ITA 1410/DEL/2023[2019-20]Status: DisposedITAT Delhi30 May 2024AY 2019-20

Bench: Shri Saktijit Dey, Vice- & Shri Brajesh Kumar Singh

…sessment years and the impugned assessment years, learned first appellate authority has decided the issue in favour of the assessee, observing as under: “5.4 Further placing reliance on the Article 7 of DTAA, Amadeus Global Travel Distribution S.A. Vs. DCIT 113 TTJ 767 (Del.) by the coordinate Bench of the Tribunal which has been affirmed by the Hon’ble Delhi High Court in ITA 689/2011 & 795-797/2011 by relying upon the decision held in case of DIT Vs. Galileo International Inc. 224 CTR 251 (Del.) wherein it is held as under: “it is to be noted that even in the first assessment framed by the Assessing Officer,…

DCIT CIRCLE-3(1)(1). INTL. TAXATION , NEW DELHI vs. RICARDO UK LTD., NEW DELHI

In the result, the appeals are dismissed

ITA 1409/DEL/2023[2018-19]Status: DisposedITAT Delhi30 May 2024AY 2018-19

Bench: Shri Saktijit Dey, Vice- & Shri Brajesh Kumar Singh

…sessment years and the impugned assessment years, learned first appellate authority has decided the issue in favour of the assessee, observing as under: “5.4 Further placing reliance on the Article 7 of DTAA, Amadeus Global Travel Distribution S.A. Vs. DCIT 113 TTJ 767 (Del.) by the coordinate Bench of the Tribunal which has been affirmed by the Hon’ble Delhi High Court in ITA 689/2011 & 795-797/2011 by relying upon the decision held in case of DIT Vs. Galileo International Inc. 224 CTR 251 (Del.) wherein it is held as under: “it is to be noted that even in the first assessment framed by the Assessing Officer,…

DCIT, CIRCLE-3(1)(1), INTL. TAXATION, NEW DELHI vs. RICARDO UK LTD., NEW DELHI

In the result, the appeals are dismissed

ITA 1408/DEL/2023[2017-18]Status: DisposedITAT Delhi30 May 2024AY 2017-18

Bench: Shri Saktijit Dey, Vice- & Shri Brajesh Kumar Singh

…sessment years and the impugned assessment years, learned first appellate authority has decided the issue in favour of the assessee, observing as under: “5.4 Further placing reliance on the Article 7 of DTAA, Amadeus Global Travel Distribution S.A. Vs. DCIT 113 TTJ 767 (Del.) by the coordinate Bench of the Tribunal which has been affirmed by the Hon’ble Delhi High Court in ITA 689/2011 & 795-797/2011 by relying upon the decision held in case of DIT Vs. Galileo International Inc. 224 CTR 251 (Del.) wherein it is held as under: “it is to be noted that even in the first assessment framed by the Assessing Officer,…

SABRE GLBL INC.,NEW DELHI vs. ACIT (INTERNATIONAL TAXATION), CIRCLE- 3(1)(2), NEW DELHI

In the result, all the appeals of the assessee are allowed and that of the Revenue stands dismissed

ITA 6040/DEL/2019[2016-17]Status: HeardITAT Delhi09 Feb 2024AY 2016-17

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmaita No. 216/Del/2016, A.Y. 2012-13 Ita No. 559/Del/2017, A.Y. 2013-14 Ita No. 4838/Del/2017, A.Y. 2014-15 Ita No. 7724/Del/2018, A.Y. 2015-16 Ita No. 6040/Del/2019, A.Y. 2016-17 Sabre Glbl Inc. Vs. Asstt. Commissioner Of Income Mr. Tarandeep Singh, Tax, Adv. Circle-3(1)(2), C/O. Ms Associates, International Tax F-99, Lajpat Nagar-Ii, New Delhi New Delhi Pan : Aaact7216Q (Appellant) (Respondent) Deputy Commissioner Of Vs. Sabre Glbl Inc. Income Tax, Mr. Tarandeep Singh, Adv. International Taxation, C/O. Ms Associates, New Delhi F-99, Lajpat Nagar-Ii, New Delhi-110024 Pan : Aaact7216Q (Appellant) (Respondent) Assessee By Sh. Tarandeep Singh, Adv. Revenue By Sh. Vizay B. Vasanta, Cit-Dr

Section 143(2)Section 143(3)Section 144C(1)

…order of Delhi Tribunal. It was submitted that the above position had also been upheld by Hon'ble Delhi High Court in the case of Galileo International Inc. v. DCIT 19 SOT 257 and Mumbai Tribunal in the case of Amadeus Global Travel Distribution S.A. v. DCIT 113 TTJ 767, the facts of which are similar to assessee's old business operation model applicable till February 2005. 12. Accordingly, in deference to the view of the Hon'ble High Court & Tribunal, the DRP directed the AO to follow suit. It directed that the AO shall carry out the attribution as directed by the Tribunal in case of the assessee for the prior…

SABRE GLBL INC.,NEW DELHI vs. ACIT (INTERNATIONAL TAXATION), CIRCLE- 3(1)(2), NEW DELHI

In the result, all the appeals of the assessee are allowed and that of the Revenue stands dismissed

ITA 7724/DEL/2018[2015-16]Status: HeardITAT Delhi09 Feb 2024AY 2015-16

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmaita No. 216/Del/2016, A.Y. 2012-13 Ita No. 559/Del/2017, A.Y. 2013-14 Ita No. 4838/Del/2017, A.Y. 2014-15 Ita No. 7724/Del/2018, A.Y. 2015-16 Ita No. 6040/Del/2019, A.Y. 2016-17 Sabre Glbl Inc. Vs. Asstt. Commissioner Of Income Mr. Tarandeep Singh, Tax, Adv. Circle-3(1)(2), C/O. Ms Associates, International Tax F-99, Lajpat Nagar-Ii, New Delhi New Delhi Pan : Aaact7216Q (Appellant) (Respondent) Deputy Commissioner Of Vs. Sabre Glbl Inc. Income Tax, Mr. Tarandeep Singh, Adv. International Taxation, C/O. Ms Associates, New Delhi F-99, Lajpat Nagar-Ii, New Delhi-110024 Pan : Aaact7216Q (Appellant) (Respondent) Assessee By Sh. Tarandeep Singh, Adv. Revenue By Sh. Vizay B. Vasanta, Cit-Dr

Section 143(2)Section 143(3)Section 144C(1)

…order of Delhi Tribunal. It was submitted that the above position had also been upheld by Hon'ble Delhi High Court in the case of Galileo International Inc. v. DCIT 19 SOT 257 and Mumbai Tribunal in the case of Amadeus Global Travel Distribution S.A. v. DCIT 113 TTJ 767, the facts of which are similar to assessee's old business operation model applicable till February 2005. 12. Accordingly, in deference to the view of the Hon'ble High Court & Tribunal, the DRP directed the AO to follow suit. It directed that the AO shall carry out the attribution as directed by the Tribunal in case of the assessee for the prior…

SABRE GLBL INC.,NEW DELHI vs. DCIT (INTERNATIONAL TAXATION), NEW DELHI

In the result, all the appeals of the assessee are allowed and that of the Revenue stands dismissed

ITA 559/DEL/2017[2013-14]Status: HeardITAT Delhi09 Feb 2024AY 2013-14

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmaita No. 216/Del/2016, A.Y. 2012-13 Ita No. 559/Del/2017, A.Y. 2013-14 Ita No. 4838/Del/2017, A.Y. 2014-15 Ita No. 7724/Del/2018, A.Y. 2015-16 Ita No. 6040/Del/2019, A.Y. 2016-17 Sabre Glbl Inc. Vs. Asstt. Commissioner Of Income Mr. Tarandeep Singh, Tax, Adv. Circle-3(1)(2), C/O. Ms Associates, International Tax F-99, Lajpat Nagar-Ii, New Delhi New Delhi Pan : Aaact7216Q (Appellant) (Respondent) Deputy Commissioner Of Vs. Sabre Glbl Inc. Income Tax, Mr. Tarandeep Singh, Adv. International Taxation, C/O. Ms Associates, New Delhi F-99, Lajpat Nagar-Ii, New Delhi-110024 Pan : Aaact7216Q (Appellant) (Respondent) Assessee By Sh. Tarandeep Singh, Adv. Revenue By Sh. Vizay B. Vasanta, Cit-Dr

Section 143(2)Section 143(3)Section 144C(1)

…order of Delhi Tribunal. It was submitted that the above position had also been upheld by Hon'ble Delhi High Court in the case of Galileo International Inc. v. DCIT 19 SOT 257 and Mumbai Tribunal in the case of Amadeus Global Travel Distribution S.A. v. DCIT 113 TTJ 767, the facts of which are similar to assessee's old business operation model applicable till February 2005. 12. Accordingly, in deference to the view of the Hon'ble High Court & Tribunal, the DRP directed the AO to follow suit. It directed that the AO shall carry out the attribution as directed by the Tribunal in case of the assessee for the prior…

SABRE GLBL INC.,NEW DELHI vs. DCIT (INTERNATIONAL TAXATION), CIRCLE- 3(1)(2), NEW DELHI

In the result, all the appeals of the assessee are allowed and that of the Revenue stands dismissed

ITA 4838/DEL/2017[2014-15]Status: HeardITAT Delhi09 Feb 2024AY 2014-15

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmaita No. 216/Del/2016, A.Y. 2012-13 Ita No. 559/Del/2017, A.Y. 2013-14 Ita No. 4838/Del/2017, A.Y. 2014-15 Ita No. 7724/Del/2018, A.Y. 2015-16 Ita No. 6040/Del/2019, A.Y. 2016-17 Sabre Glbl Inc. Vs. Asstt. Commissioner Of Income Mr. Tarandeep Singh, Tax, Adv. Circle-3(1)(2), C/O. Ms Associates, International Tax F-99, Lajpat Nagar-Ii, New Delhi New Delhi Pan : Aaact7216Q (Appellant) (Respondent) Deputy Commissioner Of Vs. Sabre Glbl Inc. Income Tax, Mr. Tarandeep Singh, Adv. International Taxation, C/O. Ms Associates, New Delhi F-99, Lajpat Nagar-Ii, New Delhi-110024 Pan : Aaact7216Q (Appellant) (Respondent) Assessee By Sh. Tarandeep Singh, Adv. Revenue By Sh. Vizay B. Vasanta, Cit-Dr

Section 143(2)Section 143(3)Section 144C(1)

…order of Delhi Tribunal. It was submitted that the above position had also been upheld by Hon'ble Delhi High Court in the case of Galileo International Inc. v. DCIT 19 SOT 257 and Mumbai Tribunal in the case of Amadeus Global Travel Distribution S.A. v. DCIT 113 TTJ 767, the facts of which are similar to assessee's old business operation model applicable till February 2005. 12. Accordingly, in deference to the view of the Hon'ble High Court & Tribunal, the DRP directed the AO to follow suit. It directed that the AO shall carry out the attribution as directed by the Tribunal in case of the assessee for the prior…

SABRE INC,NEW DELHI vs. DCIT (INTERNATIONAL TAXATION), NEW DELHI

In the result, all the appeals of the assessee are allowed and that of the Revenue stands dismissed

ITA 216/DEL/2016[2012-13]Status: HeardITAT Delhi09 Feb 2024AY 2012-13

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmaita No. 216/Del/2016, A.Y. 2012-13 Ita No. 559/Del/2017, A.Y. 2013-14 Ita No. 4838/Del/2017, A.Y. 2014-15 Ita No. 7724/Del/2018, A.Y. 2015-16 Ita No. 6040/Del/2019, A.Y. 2016-17 Sabre Glbl Inc. Vs. Asstt. Commissioner Of Income Mr. Tarandeep Singh, Tax, Adv. Circle-3(1)(2), C/O. Ms Associates, International Tax F-99, Lajpat Nagar-Ii, New Delhi New Delhi Pan : Aaact7216Q (Appellant) (Respondent) Deputy Commissioner Of Vs. Sabre Glbl Inc. Income Tax, Mr. Tarandeep Singh, Adv. International Taxation, C/O. Ms Associates, New Delhi F-99, Lajpat Nagar-Ii, New Delhi-110024 Pan : Aaact7216Q (Appellant) (Respondent) Assessee By Sh. Tarandeep Singh, Adv. Revenue By Sh. Vizay B. Vasanta, Cit-Dr

Section 143(2)Section 143(3)Section 144C(1)

…order of Delhi Tribunal. It was submitted that the above position had also been upheld by Hon'ble Delhi High Court in the case of Galileo International Inc. v. DCIT 19 SOT 257 and Mumbai Tribunal in the case of Amadeus Global Travel Distribution S.A. v. DCIT 113 TTJ 767, the facts of which are similar to assessee's old business operation model applicable till February 2005. 12. Accordingly, in deference to the view of the Hon'ble High Court & Tribunal, the DRP directed the AO to follow suit. It directed that the AO shall carry out the attribution as directed by the Tribunal in case of the assessee for the prior…

DCIT (INTERNATIONAL TAXATION), NEW DELHI vs. M/S. SABRE GLBL INC., GURGAON

In the result, all the appeals of the assessee are allowed and that of the Revenue stands dismissed

ITA 6731/DEL/2015[2012-13]Status: HeardITAT Delhi09 Feb 2024AY 2012-13

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmaita No. 216/Del/2016, A.Y. 2012-13 Ita No. 559/Del/2017, A.Y. 2013-14 Ita No. 4838/Del/2017, A.Y. 2014-15 Ita No. 7724/Del/2018, A.Y. 2015-16 Ita No. 6040/Del/2019, A.Y. 2016-17 Sabre Glbl Inc. Vs. Asstt. Commissioner Of Income Mr. Tarandeep Singh, Tax, Adv. Circle-3(1)(2), C/O. Ms Associates, International Tax F-99, Lajpat Nagar-Ii, New Delhi New Delhi Pan : Aaact7216Q (Appellant) (Respondent) Deputy Commissioner Of Vs. Sabre Glbl Inc. Income Tax, Mr. Tarandeep Singh, Adv. International Taxation, C/O. Ms Associates, New Delhi F-99, Lajpat Nagar-Ii, New Delhi-110024 Pan : Aaact7216Q (Appellant) (Respondent) Assessee By Sh. Tarandeep Singh, Adv. Revenue By Sh. Vizay B. Vasanta, Cit-Dr

Section 143(2)Section 143(3)Section 144C(1)

…order of Delhi Tribunal. It was submitted that the above position had also been upheld by Hon'ble Delhi High Court in the case of Galileo International Inc. v. DCIT 19 SOT 257 and Mumbai Tribunal in the case of Amadeus Global Travel Distribution S.A. v. DCIT 113 TTJ 767, the facts of which are similar to assessee's old business operation model applicable till February 2005. 12. Accordingly, in deference to the view of the Hon'ble High Court & Tribunal, the DRP directed the AO to follow suit. It directed that the AO shall carry out the attribution as directed by the Tribunal in case of the assessee for the prior…

THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -2 vs. TRAVELPORT L.P. USA

Of the process

ITA/301/2022HC Delhi02 Sept 2022

Bench: HON'BLE MR. JUSTICE MANMOHAN,HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA

…has not deployed any assets in India. 7. The ITAT in the present case not only relied upon the judgment of this Court in Galileo International (Supra) but also relied on the judgment of its Coordinate Bench in Amadeus Global Travel I Distribution S.A. v. DCIT 113 TTJ 767. 8. In the impugned order, the ITAT held that the present case was similar to that of Galileo International (Supra) and that the CIT(A) rightly attributed 15% of the revenue to the Respondent’s PE in India. In fact, the This is a digitally signed Judgement. NEUTRAL CITATION NO: 2022/DHC/003465 ITA 301/2022 Page 3 of 3 Appellant has not brought…