SC held that Question as to what proportion of Profit is attributable to India is question of fact

Director of Income-tax v. Travelport Inc. – [2023] 149 470 (SC) Facts: The taxpayers are engaged in the business of providing electronic global distribution services to Airlines through “Computerized Reservation System” (CRS). The taxpayers maintain and operate a Master Computer System consisting of several main frame computers and servers located in other countries, including […]

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