https://www.taxtmi.com/caselaws?id=430207 Payments for centralized services were held not to constitute fee for technical services under Section 9(1)(vii) of the Income-tax Act or fee for included services under Article 12(4)(a) of the Indo-US DTAA, because the issue was already covered by the Court's earlier decision in Sheraton International Inc. The Revenue failed to distinguish the facts, and the pending Supreme Court challenge did not affect the binding force of that decision in the absence of any stay. The appeals were dismissed as covered by the prior ruling in favour of the assessee. en-us Fri, 04 Nov 2022 00:00:00 +0530 Mon, 02 Jan 2023 14:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=430207 Payments for centralized services were held not to constitute fee for technical services under Section 9(1)(vii) of the Income-tax Act or fee for included services under Article 12(4)(a) of the Indo-US DTAA, because the issue was already covered by the Court's earlier decision in Sheraton International Inc. The Revenue failed to distinguish the facts, and the pending Supreme Court challenge did not affect the binding force of that decision in the absence of any stay. The appeals were dismissed as covered by the prior ruling in favour of the assessee. Case-Laws Income Tax Fri, 04 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=430207