https://www.taxtmi.com/caselaws?id=255460 Interdependent Marriott agreements were treated as a single commercial arrangement, and the receipts described as sales and marketing services, fees and reimbursements were not accepted as cost-to-cost reimbursements; they were viewed in substance as brand-related income requiring examination as royalty under the Indo-US DTAA. The Tribunal also held that the correct person in whose hands the income should be assessed needed further determination by the AO. For interest, where tax was deductible at source on the receipts, advance tax liability was reduced accordingly and interest under section 234B was not sustainable. 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 Interdependent Marriott agreements were treated as a single commercial arrangement, and the receipts described as sales and marketing services, fees and reimbursements were not accepted as cost-to-cost reimbursements; they were viewed in substance as brand-related income requiring examination as royalty under the Indo-US DTAA. The Tribunal also held that the correct person in whose hands the income should be assessed needed further determination by the AO. For interest, where tax was deductible at source on the receipts, advance tax liability was reduced accordingly and interest under section 234B was not sustainable. Case-Laws Income Tax Wed, 14 Jan 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=255460