https://www.taxtmi.com/caselaws?id=312089 Royalty from use of the Marriott trademark was examined in light of a registration certificate showing Marriott Worldwide Corporation as the registered owner during the relevant period. The Tribunal observed that where the brand owner is outside India, income from the brand would ordinarily be taxable in the owner's hands, but it also required verification of who actually received the sums on behalf of the non-resident, whether the assessee could be treated as an agent under section 163, and whether withholding obligations under section 195 were complied with. The matter was restored to the Assessing Officer for fresh decision after considering the trademark registration and related material. en-us Fri, 06 May 2022 00:00:00 +0530 Wed, 31 Jan 2024 17:08:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=312089 Royalty from use of the Marriott trademark was examined in light of a registration certificate showing Marriott Worldwide Corporation as the registered owner during the relevant period. The Tribunal observed that where the brand owner is outside India, income from the brand would ordinarily be taxable in the owner's hands, but it also required verification of who actually received the sums on behalf of the non-resident, whether the assessee could be treated as an agent under section 163, and whether withholding obligations under section 195 were complied with. The matter was restored to the Assessing Officer for fresh decision after considering the trademark registration and related material. Case-Laws Income Tax Fri, 06 May 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=312089