https://www.taxtmi.com/caselaws?id=431128 Centralized services fee received from Indian hotels was held not to fall within Article 12(4)(a) or Article 12(4)(b) of the India-USA DTAA and not to constitute fees for technical services under the Act. The Tribunal followed its earlier decision in the assessee's own case, which itself had applied binding jurisdictional precedent in the group concern's matter. The receipt was treated as business income, and because the assessee had no permanent establishment in India, the income was not taxable in India. The addition was therefore deleted in favour of the assessee. en-us Thu, 21 Jul 2022 00:00:00 +0530 Tue, 06 Dec 2022 13:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=431128 Centralized services fee received from Indian hotels was held not to fall within Article 12(4)(a) or Article 12(4)(b) of the India-USA DTAA and not to constitute fees for technical services under the Act. The Tribunal followed its earlier decision in the assessee's own case, which itself had applied binding jurisdictional precedent in the group concern's matter. The receipt was treated as business income, and because the assessee had no permanent establishment in India, the income was not taxable in India. The addition was therefore deleted in favour of the assessee. Case-Laws Income Tax Thu, 21 Jul 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=431128