https://www.taxtmi.com/caselaws?id=312292 Marketing and reservation contribution fees received from Indian hotels were treated as earmarked amounts subject to a corresponding obligation to use them for agreed marketing and reservation purposes, rather than as unrestricted income. The same receipts had earlier been held not to constitute income and not to be chargeable as business profits in the absence of a permanent establishment in India. On that basis, the later assessment also accepted that the amount was not chargeable in India, and the deletion of the addition was upheld in favour of the assessee. en-us Wed, 30 Mar 2011 00:00:00 +0530 Sat, 10 Feb 2024 10:53:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=312292 Marketing and reservation contribution fees received from Indian hotels were treated as earmarked amounts subject to a corresponding obligation to use them for agreed marketing and reservation purposes, rather than as unrestricted income. The same receipts had earlier been held not to constitute income and not to be chargeable as business profits in the absence of a permanent establishment in India. On that basis, the later assessment also accepted that the amount was not chargeable in India, and the deletion of the addition was upheld in favour of the assessee. Case-Laws Income Tax Wed, 30 Mar 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=312292