What is DIT v. Galileo International Inc. authority for?

If the income attributable to a Permanent Establishment (PE) in India is less than the remuneration paid to a dependent agent, the assessment is extinguished and no further computation of income is required.

How many judgments cite DIT v. Galileo International Inc.?

37 judgments on BharatTax cite DIT v. Galileo International Inc. (224 CTR 251), spanning 2011 to 2024.

Which sections of the Income Tax Act does DIT v. Galileo International Inc. come up under?

It is most often cited in judgments turning on Section 1961 Section 9(1)(i), Section 1961 Sections 44BB, Section 1962, Section 1962 - Rule 10, Section 1962 Rule 10, Section 44BBA.

DIT v. Galileo International Inc. (224 CTR 251)

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

…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, the entire expenses in the form of remuneration paid to AIPL was held as allowable deduction and was reduced while computing the income of appellant if that be the case, the income attributable to PE in India being less than…

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

…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, the entire expenses in the form of remuneration paid to AIPL was held as allowable deduction and was reduced while computing the income of appellant if that be the case, the income attributable to PE in India being less than…

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

…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, the entire expenses in the form of remuneration paid to AIPL was held as allowable deduction and was reduced while computing the income of appellant if that be the case, the income attributable to PE in India being less than…