https://www.taxtmi.com/caselaws?id=410491 Receipts from centralized hotel management and related support services were treated as part of an integrated business arrangement, not as independent technical or consultancy services under section 9 of the Income-tax Act or Article 12 of the India-US DTAA. The Tribunal relied on its earlier order in the assessee's own case and the binding Delhi High Court decision in Sheraton, and held that the Revenue's fresh Article 12 theory could not displace that position. In the absence of a permanent establishment, the receipts continued to be characterised as business profits, and the Assessing Officer's additions were not sustainable. en-us Fri, 30 Jul 2021 00:00:00 +0530 Mon, 02 Aug 2021 10:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=410491 Receipts from centralized hotel management and related support services were treated as part of an integrated business arrangement, not as independent technical or consultancy services under section 9 of the Income-tax Act or Article 12 of the India-US DTAA. The Tribunal relied on its earlier order in the assessee's own case and the binding Delhi High Court decision in Sheraton, and held that the Revenue's fresh Article 12 theory could not displace that position. In the absence of a permanent establishment, the receipts continued to be characterised as business profits, and the Assessing Officer's additions were not sustainable. Case-Laws Income Tax Fri, 30 Jul 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=410491