Amadeus IT Group SA vs. ACIT, Circle-1(1)(1), International Taxation, New Delhi for AY 2019-20

Amadeus IT Group SA vs. ACIT, Circle-1(1)(1), International Taxation, New Delhi for Assessment Year 2019-20

Case Number: ITA No. 1466/DEL/2022

Appellant: Amadeus IT Group SA

Respondent: ACIT, Circle-1(1)(1), International Taxation, New Delhi

This document provides a comprehensive analysis of the income tax appellate tribunal decision for the case specified above, reflecting on the key aspects, arguments, tribunal decision, and its implications. The analysis covers significant legal points, evidence presented, and the rationale behind the tribunal’s conclusion.

The tribunal adjudicated on several grounds including the computation of income, the existence of a permanent establishment, royalty income, and the attribution of profits to the permanent establishment in India. The decision also delved into the applicability of international tax agreements, specifically the Indo-Spain Double Taxation Avoidance Agreement (DTAA), and its interpretation in the context of the case. This complex case sheds light on intricate aspects of international taxation, the use of computer reservation systems (CRS) by multinational corporations operating across borders, and the associated tax liabilities in the host country, which in this instance is India.

Background

The case pertains to the assessment year 2019-20…

For detailed insights on each of the arguments, tribunal findings, and the judicial reasoning behind the decision, referring to the full case documentation and legal commentary is recommended.

Amadeus IT Group SA vs. ACIT, Circle-1(1)(1), International Taxation, New Delhi for AY 2019-20