https://www.taxtmi.com/caselaws?id=296667 Receipts for sales, marketing, reservation, technological, operational, loyalty and training-related services were analysed under section 9(1)(vii) and Article 12 of the India-US DTAA. Applying the jurisdictional HC ruling in the assessee's own case, the Tribunal treated the arrangement as an integrated business service for mutual commercial benefit, with trademark use, reservation systems and related programmes being incidental. Because the services did not make technology available to the Indian hotels, the receipts were not fees for technical services, not royalty, and were instead business income; in the absence of a permanent establishment, they were not taxable in India. en-us Thu, 17 Oct 2019 00:00:00 +0530 Mon, 02 Aug 2021 09:02:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=296667 Receipts for sales, marketing, reservation, technological, operational, loyalty and training-related services were analysed under section 9(1)(vii) and Article 12 of the India-US DTAA. Applying the jurisdictional HC ruling in the assessee's own case, the Tribunal treated the arrangement as an integrated business service for mutual commercial benefit, with trademark use, reservation systems and related programmes being incidental. Because the services did not make technology available to the Indian hotels, the receipts were not fees for technical services, not royalty, and were instead business income; in the absence of a permanent establishment, they were not taxable in India. Case-Laws Income Tax Thu, 17 Oct 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=296667