Director of Income-tax v. Travelport Inc. – [2023] 149 taxmann.com 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 […]
SECTION 260A – SUBSTANTIAL QUESTION OF LAW IN CONTEXT OF TP
As per section 260A of the Income Tax Act, an appeal shall lie to the High Court from order passed by ITAT, if the High Court is satisfied that the case involves a substantial question of law. In the context of Transfer Pricing, an issue arises that what circumstances substantial question of law arises. This […]