https://www.taxtmi.com/caselaws?id=210080 Marketing and reservation contributions received under a hotel franchise arrangement for common marketing and centralized reservation facilities were held not to be taxable in India. The receipts were earmarked for agreed purposes and were not an unfettered income stream. Following the assessee's earlier case, the same view was applied that, in the absence of a permanent establishment in India, the amounts could not be taxed as business profits under Article 7 of the Indo-US DTAA and did not constitute royalty or fee for included services under Article 12. en-us Wed, 11 May 2011 00:00:00 +0530 Fri, 10 Feb 2012 11:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=210080 Marketing and reservation contributions received under a hotel franchise arrangement for common marketing and centralized reservation facilities were held not to be taxable in India. The receipts were earmarked for agreed purposes and were not an unfettered income stream. Following the assessee's earlier case, the same view was applied that, in the absence of a permanent establishment in India, the amounts could not be taxed as business profits under Article 7 of the Indo-US DTAA and did not constitute royalty or fee for included services under Article 12. Case-Laws Income Tax Wed, 11 May 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=210080