https://www.taxtmi.com/caselaws?id=297541 Centralised services fee received for hotel-related support services was treated as business income rather than royalty or fee for technical services under the Income-tax Act and the India-US DTAA. The services, including advertising, publicity, sales promotion and allied support functions, were regarded as incidental to the commercial arrangement and not as services giving rise to royalty or technical fee character. In the absence of a permanent establishment in India, the receipts were not taxable in India. The analysis followed the jurisdictional High Court ruling in the assessee's own case and the consistent view taken for earlier years. en-us Mon, 18 Nov 2019 00:00:00 +0530 Fri, 10 Sep 2021 02:19:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=297541 Centralised services fee received for hotel-related support services was treated as business income rather than royalty or fee for technical services under the Income-tax Act and the India-US DTAA. The services, including advertising, publicity, sales promotion and allied support functions, were regarded as incidental to the commercial arrangement and not as services giving rise to royalty or technical fee character. In the absence of a permanent establishment in India, the receipts were not taxable in India. The analysis followed the jurisdictional High Court ruling in the assessee's own case and the consistent view taken for earlier years. Case-Laws Income Tax Mon, 18 Nov 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=297541