The mere function of booking the tickets can’t be considered a significant business activity. Travel agents working in India only book the tickets and aren’t capable of processing all of the airlines’ data at one location. This function of only booking as held by the division bench of Justice Manmohan and Justice Manmeet Pritam Singh Arora is not a substantial business activity and therefore, is not taxable. “The mere function of booking the tickets isn’t a considerable business activity”, said Delhi HC

Case Title: CIT Versus Travelport L.P. USA