https://www.taxtmi.com/caselaws?id=63302 An integrated hotel marketing and reservation arrangement was held not to give rise to royalty or fees for included services because trademark use was incidental and no technical knowledge was made available in the treaty sense; the receipts were treated as business profits and, absent a permanent establishment, were not taxable in India. Reassessment for years with no original regular assessment was upheld because there was no prior opinion to amount to a change of opinion. In remand proceedings, the Assessing Officer could not tax amounts that had already attained finality outside the subject matter of appeal. Interest under section 234B was not leviable where tax was deductible at source, and SCI/SPG and FFP contributions were also held not taxable. en-us Wed, 04 Oct 2006 00:00:00 +0530 Tue, 30 Nov 2021 16:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=63302 An integrated hotel marketing and reservation arrangement was held not to give rise to royalty or fees for included services because trademark use was incidental and no technical knowledge was made available in the treaty sense; the receipts were treated as business profits and, absent a permanent establishment, were not taxable in India. Reassessment for years with no original regular assessment was upheld because there was no prior opinion to amount to a change of opinion. In remand proceedings, the Assessing Officer could not tax amounts that had already attained finality outside the subject matter of appeal. Interest under section 234B was not leviable where tax was deductible at source, and SCI/SPG and FFP contributions were also held not taxable. Case-Laws Income Tax Wed, 04 Oct 2006 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=63302