https://www.taxtmi.com/caselaws?id=428550 Centralized services fees received under an integrated hotel arrangement were treated as business receipts rather than royalty or fees for technical services, because the services comprised advertising, publicity, marketing, reservation support and related functions rendered for mutual business benefit, with trademarks, brand names and reservation systems used only incidentally. The Tribunal followed the assessee's earlier years and the jurisdictional High Court in holding that, absent a permanent establishment in India, the receipts were not chargeable to tax as business profits either. The related interest issue did not survive once the principal tax addition failed. en-us Fri, 23 Sep 2022 00:00:00 +0530 Mon, 03 Oct 2022 16:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=428550 Centralized services fees received under an integrated hotel arrangement were treated as business receipts rather than royalty or fees for technical services, because the services comprised advertising, publicity, marketing, reservation support and related functions rendered for mutual business benefit, with trademarks, brand names and reservation systems used only incidentally. The Tribunal followed the assessee's earlier years and the jurisdictional High Court in holding that, absent a permanent establishment in India, the receipts were not chargeable to tax as business profits either. The related interest issue did not survive once the principal tax addition failed. Case-Laws Income Tax Fri, 23 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=428550