https://www.taxtmi.com/caselaws?id=210080 The Tribunal ruled that marketing and reservation contributions received by a non-resident company from Indian hotel owners do not qualify as Royalty or Fee for Included Services under the Indo-US Double Taxation Avoidance Agreement. As the company lacks a Permanent Establishment in India, the contributions were deemed as business income and not subject to taxation in India. Consequently, the appeals by the company were successful, and the addition of these charges as taxable income was overturned. 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 The Tribunal ruled that marketing and reservation contributions received by a non-resident company from Indian hotel owners do not qualify as Royalty or Fee for Included Services under the Indo-US Double Taxation Avoidance Agreement. As the company lacks a Permanent Establishment in India, the contributions were deemed as business income and not subject to taxation in India. Consequently, the appeals by the company were successful, and the addition of these charges as taxable income was overturned. Case-Laws Income Tax Wed, 11 May 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=210080