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The ITAT allowed the assessee's appeals, holding that receipts characterized as marketing, distribution marketing, frequency marketing programme and SCHI facility charges do not constitute royalty, FTS or FIS under s.9(1)(vii) or Article 12(4)(a) of the India-USA DTAA. The Tribunal applied the consistency doctrine, noting unchanged facts and prior favourable tribunal orders in the assessee's own cases, and found no material warranting a different conclusion for the impugned year. Similarly, amounts billed as travel agent commission for bookings of third-party Indian hotels were held not to be managerial, technical or consultancy fees and thus not taxable as FTS/FIS. All contested additions were therefore deleted.
The ITAT allowed the assessee's appeals, holding that receipts characterized as marketing, distribution marketing, frequency marketing programme and SCHI facility charges do not constitute royalty, FTS or FIS under s.9(1)(vii) or Article 12(4)(a) of the India-USA DTAA. The Tribunal applied the consistency doctrine, noting unchanged facts and prior favourable tribunal orders in the assessee's own cases, and found no material warranting a different conclusion for the impugned year. Similarly, amounts billed as travel agent commission for bookings of third-party Indian hotels were held not to be managerial, technical or consultancy fees and thus not taxable as FTS/FIS. All contested additions were therefore deleted.
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