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The ITAT allowed the appeals in part. It held that marketing reservation charges (MRC) are not taxable as royalty or fees for included services, and the Tribunal's coordinate-bench precedent was applied to allow the relevant grounds. Receipts characterized as reimbursements or travel-agent commission programs (TACP) for third-party hotel bookings do not constitute managerial, technical or consultancy services and are not FTS under s.9(1)(vii) or the India-US DTAA. Regarding short grant of TDS credit, the ITAT remanded the matter to the assessing officer to examine and grant TDS credit or consider refund claims in accordance with law after hearing the assessee.
The ITAT allowed the appeals in part. It held that marketing reservation charges (MRC) are not taxable as royalty or fees for included services, and the Tribunal's coordinate-bench precedent was applied to allow the relevant grounds. Receipts characterized as reimbursements or travel-agent commission programs (TACP) for third-party hotel bookings do not constitute managerial, technical or consultancy services and are not FTS under s.9(1)(vii) or the India-US DTAA. Regarding short grant of TDS credit, the ITAT remanded the matter to the assessing officer to examine and grant TDS credit or consider refund claims in accordance with law after hearing the assessee.
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