Taxability of centralized fee rejected where prior coordinate bench rulings covered the issue and no substantial question of law arose.

Centralized fee comprising sales and marketing charges, loyalty programme receipts, reservation charges, technological services, operational services and training or human resource services was treated as not taxable, as the Tribunal's view was already covered by an earlier coordinate bench ruling and had been followed in the assessee's own case for another year. On that basis, the Delhi HC held that no substantial question of law arose in the revenue's appeal and left the Tribunal's decision in favour of the assessee undisturbed.

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Issues: Whether the centralized fee earned by the respondent was taxable and whether any substantial question of law arose in the revenue's appeal.

Analysis: The Tribunal had held that the centralized fee, comprising amounts relating to sales and marketing charges, loyalty programmes, reservation charges, technological services, operational services and training or human resource services, was not taxable. That view was found to be covered by an earlier coordinate bench decision, and the same approach had also been followed in the respondent's own case for another assessment year.

Conclusion: No substantial question of law arose. The appeal was therefore closed, resulting in no interference with the Tribunal's view in favour of the assessee.

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