https://www.taxtmi.com/caselaws?id=211461 Identical receipts from hotel-related marketing, reservation, advertising and loyalty programme services were treated as business income, not royalty or fees for technical services, because earlier decisions in the assessee's own case had already reached that conclusion and the jurisdictional High Court had rejected the Revenue's challenge. With no permanent establishment in India, Article 7 of the India-USA DTAA barred taxation of those business profits in India. The characterisation under section 9(1)(vi) and section 9(1)(vii) of the Income-tax Act did not change that result, so the additions were deleted and the Revenue's appeals failed. en-us Tue, 31 Jan 2012 00:00:00 +0530 Fri, 24 May 2013 12:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=211461 Identical receipts from hotel-related marketing, reservation, advertising and loyalty programme services were treated as business income, not royalty or fees for technical services, because earlier decisions in the assessee's own case had already reached that conclusion and the jurisdictional High Court had rejected the Revenue's challenge. With no permanent establishment in India, Article 7 of the India-USA DTAA barred taxation of those business profits in India. The characterisation under section 9(1)(vi) and section 9(1)(vii) of the Income-tax Act did not change that result, so the additions were deleted and the Revenue's appeals failed. Case-Laws Income Tax Tue, 31 Jan 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=211461