https://www.taxtmi.com/caselaws?id=255460 The Tribunal held that the amounts received by the assessee under the International Sales and Marketing Agreement (ISMA) are taxable as "Royalty" under the Indo-US tax treaty, rejecting the assessee's claim that they were reimbursements for marketing expenses. The Tribunal found that these payments were for the promotion and maintenance of the Marriott brand, benefiting the brand owner, and not mere reimbursements. Additionally, the Tribunal ruled that interest under Section 234B should not be levied as the amounts were subject to tax deduction at source. The appeals were partly allowed for some assessment years and dismissed for others. en-us Wed, 14 Jan 2015 00:00:00 +0530 Sat, 07 Nov 2015 17:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=255460 The Tribunal held that the amounts received by the assessee under the International Sales and Marketing Agreement (ISMA) are taxable as "Royalty" under the Indo-US tax treaty, rejecting the assessee's claim that they were reimbursements for marketing expenses. The Tribunal found that these payments were for the promotion and maintenance of the Marriott brand, benefiting the brand owner, and not mere reimbursements. Additionally, the Tribunal ruled that interest under Section 234B should not be levied as the amounts were subject to tax deduction at source. The appeals were partly allowed for some assessment years and dismissed for others. Case-Laws Income Tax Wed, 14 Jan 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=255460