Galileo International Inc. v. DCIT
19 SOT 257Income Tax Appellate Tribunal2008#3783 most cited
What is Galileo International Inc. v. DCIT authority for?
A Computer Reservation System (CRS) installed at the premises of Indian subscribers can constitute a Permanent Establishment (PE) in India, and a portion of income from Indian operations may be taxable in India, potentially exhausted by commission paid to Indian distributors.
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judgments rely on this decision, according to BharatTax’s citation analysis of 366,418 Indian tax judgments — from 2014 to 2024.
Also referred to as
Galileo International Inc. v. DCIT · 19 SOT 257 · Permanent Establishment · PE · fixed place PE · dependent agent PE · Computer Reservation System · CRS · Section 9(1)(i) · business connection · attribution of income · treaty benefits