https://www.taxtmi.com/caselaws?id=429608 Centralized service receipts under a Master Franchise Agreement were examined for characterization as royalty or fees for technical services, including fees for included services, under domestic law and the India-USA DTAA. The receipts for marketing, promotion, reservation and allied services were treated as a separate stream of consideration and not as ancillary and subsidiary to the licence fee. As they did not independently satisfy the treaty definition of fees for included services, and were not otherwise shown to be royalty or fees for technical services, the addition was deleted and the receipts were held not taxable on that basis. en-us Mon, 31 Oct 2022 00:00:00 +0530 Tue, 01 Nov 2022 11:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=429608 Centralized service receipts under a Master Franchise Agreement were examined for characterization as royalty or fees for technical services, including fees for included services, under domestic law and the India-USA DTAA. The receipts for marketing, promotion, reservation and allied services were treated as a separate stream of consideration and not as ancillary and subsidiary to the licence fee. As they did not independently satisfy the treaty definition of fees for included services, and were not otherwise shown to be royalty or fees for technical services, the addition was deleted and the receipts were held not taxable on that basis. Case-Laws Income Tax Mon, 31 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=429608