The Indian Income Tax Appellate Tribunal (ITAT) delivered a ruling dated 30 November 2007 in the case of Galileo International Inc. v. Deputy Commissioner of Income Tax on whether a person engaged in the business of providing Computerized Reservation System (CRS) services had, (i) any source of income in India, (ii) a permanent establishment (PE) in India, and (iii) if the PE was liable to tax in India.
(a) Facts. Galileo International Inc. (the Taxpayer) was a …