Galileo International Inc. v. DCIT

116 ITD 1Income Tax Appellate Tribunal2009#2900 most cited

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

Income is chargeable to tax in India only to the extent it is reasonably attributable to operations carried out in India, especially when the amounts paid to associated enterprises are at arm's length.

41

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2011 to 2024.

Also referred to as

Galileo International Inc. v. DCIT · section 9(1)(i) · business connection · tax treaty · Article 7 · income attribution · arm's length price · operations in India · permanent establishment · service PE

Also reported as

114 TTJ 289

Sections most often in play

Section 143(3)Section 115BBESection 142(1)Section 143(2)Section 144Section 144CSection 144C(13)Section 145(3)

Issues it is cited on

agency pesection 9(1)(i)service peroyalty incomebusiness connectionsection 9(1)(vi)tax treatypermanent establishmentmost appropriate methodsection 9(1)arm's length pricesection 92c

Judgments citing Galileo International Inc. v. DCIT

Director of Income Tax vs. Bbc Worldwise Ltd

ITA-1341/2010HC Delhi30 Sept 2011
Section 92C

…R 205 (Bom.) holding that the payment of service fee @ 15% of the gross advertisement revenue to its agent represented the price computed on the ALP principle. The judgment of this Court in the case of DIT Vs. Galileo International Incorporation, 114 TTJ 289 (Del) was also referred. It was submitted that in Galileo International Incorporation 2011:DHC:5134-DB ITA Nos.1341/2010, 703/2010, 705/2010 Page 7 of 20 (supra), this Court had referred to the CBDT‘s Circular No.742 dated 02.5.1996 wherein it was recognised that the advertising agent of the foreign telecasting companies in…