Summary
- The ITAT Delhi has partly allowed Expedia Lodging Partner Services Sarl's appeal for AY 2018-19, ruling that it does not have a dependent agent permanent establishment (DAPE) in India.
- The Tribunal upheld the approval for reassessment under Section 151 but rejected the Revenue's claim of taxable income attributed to an alleged DAPE.
- This decision follows similar findings in AY 2022-23, reinforcing that Expedia's operations do not constitute a taxable presence in India.
- The implications of this ruling could reshape how international companies assess their tax obligations in India moving forward.
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