Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
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Income taxable in India - PE in India - Assessee was not required to manage day-to-day operations of the Hotel. - The Assessee was also required to broadly oversee the implementation of its policies. - Hyatt India was required to implement the strategic policies as set out by the Assessee. - It is clear that the said fee is not a consideration for use of or the right to use any process or for information of commercial or scientific experience. - Thus the consideration received by the Assessee in terms of SOSA cannot be termed as Royalty under Article 12 of the DTAA. It is clearly in the nature of business income. - Assessee had a PE in India in the form of a fixed place through which it carried on its business. - HC
Income taxable in India - PE in India - Assessee was not required to manage day-to-day operations of the Hotel. - The Assessee was also required to broadly oversee the implementation of its policies. - Hyatt India was required to implement the strategic policies as set out by the Assessee. - It is clear that the said fee is not a consideration for use of or the right to use any process or for information of commercial or scientific experience. - Thus the consideration received by the Assessee in terms of SOSA cannot be termed as Royalty under Article 12 of the DTAA. It is clearly in the nature of business income. - Assessee had a PE in India in the form of a fixed place through which it carried on its business. - HC
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