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    <title>2006 (11) TMI 141 - AUTHORITY FOR ADVANCE RULINGS</title>
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    <description>The Authority concluded that the amounts received by the applicant from the Indian hotel owner under the IMPPA would be taxable in India. The payments are not mere reimbursements but are in the nature of revenue receipts. The payments fall within the definition of fees for technical services (FTS) as they are for rendering managerial and consultancy services. The applicant has a business connection and a source of income in India, satisfying the requirements of Section 9(1)(i) of the Act. Therefore, the amounts received by the applicant from the Indian hotel owner in connection with the marketing and business promotion activities conducted outside India would be taxable in India.</description>
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      <title>2006 (11) TMI 141 - AUTHORITY FOR ADVANCE RULINGS</title>
      <link>https://www.taxtmi.com/caselaws?id=6600</link>
      <description>The Authority concluded that the amounts received by the applicant from the Indian hotel owner under the IMPPA would be taxable in India. The payments are not mere reimbursements but are in the nature of revenue receipts. The payments fall within the definition of fees for technical services (FTS) as they are for rendering managerial and consultancy services. The applicant has a business connection and a source of income in India, satisfying the requirements of Section 9(1)(i) of the Act. Therefore, the amounts received by the applicant from the Indian hotel owner in connection with the marketing and business promotion activities conducted outside India would be taxable in India.</description>
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