Facts of the Case
Galileo International Inc., a company incorporated in the
United States and a tax resident of the USA, operated a Computerized
Reservation System (CRS) that facilitated electronic global distribution
services for airlines, hotels, tour operators, and cab operators. The CRS
processed, stored, and disseminated information relating to flight schedules,
seat availability, fares, hotel reservations, and booking capabilities.
In India, Galileo operated through InterGlobe Enterprises
Limited under a Distribution Agreement. Travel agents in India accessed the CRS
through computer systems connected to Galileo’s global network. For every
booking made through the system, Galileo received approximately Euro 3 from
participating airlines and paid Euro 1 as commission to InterGlobe.
The Assessing Officer and the Commissioner of Income Tax
(Appeals) held that a portion of Galileo’s income arose in India and was
taxable. The Income Tax Appellate Tribunal (ITAT), while recognizing the
existence of business connection and a Permanent Establishment in India,
concluded that only a limited portion of revenue could be attributed to Indian
operations and that the commission paid to InterGlobe exhausted the profits
attributable to India. Aggrieved by this finding, the Revenue filed appeals
before the Delhi High Court.
Issues Involved
- Whether
Galileo International Inc. had income chargeable to tax in India under
Section 5(2) of the Income-tax Act.
- Whether
the assessee had a business connection in India within the meaning of
Section 9(1)(i).
- Whether
the assessee had a Permanent Establishment (PE) in India under the
India-USA DTAA.
- What
portion of income could be attributed to activities carried out in India.
- Whether
any taxable profit remained in India after considering commission paid to
the Indian agent.
- Whether
interest under Sections 234A and 234B was leviable.
Petitioner’s Arguments (Revenue)
- The
Revenue contended that the Tribunal committed an error by attributing only
15% of the revenue generated from bookings in India to Indian operations.
- It
was argued that the applicable legal principles under the DTAA and CBDT
Circular No. 23 required attribution of profits and not merely revenue.
- The
Revenue further submitted that the Tribunal wrongly reduced the attributed
income by deducting the commission paid to InterGlobe.
- It
was also argued that the conditions stipulated in paragraph 6(c) of CBDT
Circular No. 23 were not fully satisfied because certain activities were
allegedly carried out directly by the non-resident and not entirely through
its Indian agent.
Respondent’s Arguments (Galileo International
Inc.)
- The
assessee maintained that the major functions, assets, infrastructure,
databases, and risk-bearing activities were located outside India,
particularly in the USA.
- The
Indian operations were confined to facilitating booking requests through
connected terminals and travel agents.
- The
commission paid to InterGlobe represented adequate remuneration for
services rendered in India.
- Since
the commission exceeded the profit attributable to Indian operations, no
further taxable income remained in India.
- The
assessee relied upon CBDT Circular No. 23 and judicial principles
governing attribution of profits to Permanent Establishments.
Court Findings
The Delhi High Court examined the Tribunal’s findings and
observed that the Tribunal had correctly distinguished between attribution of
revenue and attribution of profits.
The Court noted that:
- Galileo
had a business connection in India.
- A
Permanent Establishment existed in India because computers and connected
systems installed at subscribers’ premises formed an integral part of the
CRS network and constituted a fixed place of business.
- The
substantial functions of collecting, processing, maintaining, and managing
reservation data were performed outside India through host computers
located in the USA.
- Indian
activities constituted only a limited segment of the overall business
operations.
The Court approved the Tribunal’s conclusion that only 15%
of the revenue attributable to bookings made in India could reasonably be
regarded as arising from Indian operations.
The Court further observed that the commission paid to
InterGlobe (Euro 1 per booking) exceeded the amount attributable to India (Euro
0.45 per booking, being 15% of Euro 3). Therefore, after allowing the
commission expenditure, no further taxable profits remained attributable to
India.
The Court relied upon:
- CBDT
Circular No. 23 dated 23.07.1969
- Morgan
Stanley & Co. (292 ITR 406)
- Hukam
Chand Mills Ltd. v. Commissioner of Income Tax (103 ITR 548)
The Court emphasized that attribution of profits is
essentially a factual exercise based upon functions performed, assets employed,
and risks assumed.
Court Order
The Delhi High Court held that no substantial question of
law arose from the Tribunal’s order.
Accordingly:
- The
appeals filed by the Revenue were dismissed.
- The
Tribunal’s findings regarding attribution of income and profit remained
undisturbed.
- It
was held that no further income was taxable in India after considering the
commission paid to InterGlobe.
Important Clarifications
- Existence
of a Permanent Establishment does not automatically result in taxable
profits in India.
- Profit
attribution must be based on functions performed, assets used, and risks
undertaken.
- Where
an Indian agent receives adequate arm’s-length remuneration, additional
profits may not be attributable to the Permanent Establishment.
- Attribution
of profits is a question of fact and cannot be interfered with unless
unsupported by evidence.
- CBDT
Circular No. 23 continues to be relevant in determining attribution of
profits in appropriate cases.
- The
distinction between attribution of revenue and attribution of profits is
crucial in international taxation matters.
Sections Involved
- Section
5(2), Income-tax Act, 1961
- Section
9(1)(i), Income-tax Act, 1961
- Sections
234A and 234B, Income-tax Act, 1961
- Article
5 (Permanent Establishment) of the India-USA Double Taxation Avoidance
Agreement (DTAA)
- CBDT Circular No. 23 dated 23.07.1969
Link to download the order -
https://delhihighcourt.nic.in/app/case_number_pdf/2009:DHC:9716-DB/AKS25022009ITA8552008_163647.pdf
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