https://www.taxtmi.com/caselaws?id=32264 Receipts from Indian hotel clients for advertising, publicity, sales promotion, reservation and allied services were treated as part of an integrated business arrangement, not as separate royalty or fees for included services. The use of the trade name, trademark and stylised mark was held incidental to the main promotional activity and not a separate monetised licence. On that basis, the receipts were characterised as business profits and, in the absence of a permanent establishment in India, were not taxable in India under the treaty. Contributions linked to the Sheraton Club International and Frequent Flyer Programmes were likewise found incidental to the same arrangement and not independently taxable as fees for included services. en-us Fri, 30 Jan 2009 00:00:00 +0530 Fri, 05 Sep 2025 14:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=32264 Receipts from Indian hotel clients for advertising, publicity, sales promotion, reservation and allied services were treated as part of an integrated business arrangement, not as separate royalty or fees for included services. The use of the trade name, trademark and stylised mark was held incidental to the main promotional activity and not a separate monetised licence. On that basis, the receipts were characterised as business profits and, in the absence of a permanent establishment in India, were not taxable in India under the treaty. Contributions linked to the Sheraton Club International and Frequent Flyer Programmes were likewise found incidental to the same arrangement and not independently taxable as fees for included services. Case-Laws Income Tax Fri, 30 Jan 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=32264