https://www.taxtmi.com/caselaws?id=297539 Centralized services fees received for marketing, advertisement and allied services to Indian hotels were treated as business/commercial receipts rather than fees for technical services or royalty. The Tribunal followed binding group-case and Delhi HC authority that such advertising, publicity and sales-promotion related services do not amount to technical services. The receipts were therefore taxable, if at all, only as business income. In the absence of a permanent establishment in India, that business income could not be taxed in India under the applicable treaty. en-us Thu, 28 Sep 2017 00:00:00 +0530 Fri, 10 Sep 2021 02:19:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=297539 Centralized services fees received for marketing, advertisement and allied services to Indian hotels were treated as business/commercial receipts rather than fees for technical services or royalty. The Tribunal followed binding group-case and Delhi HC authority that such advertising, publicity and sales-promotion related services do not amount to technical services. The receipts were therefore taxable, if at all, only as business income. In the absence of a permanent establishment in India, that business income could not be taxed in India under the applicable treaty. Case-Laws Income Tax Thu, 28 Sep 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=297539