https://www.taxtmi.com/caselaws?id=449431 ITAT Mumbai held that Marketing Contribution, Priority Club receipts, Reservation Contribution and Holidex Fees were not taxable as royalty or fee for included services where they were collected under separate arrangements for common marketing, loyalty programme, reservation support and central reservation system costs, with an obligation to apply the funds for those specified purposes. Prior coordinate bench decisions in the assessee's own case had treated similar receipts as not constituting an unfettered income stream, and the later precedent relied on by the revenue was found inapplicable on these facts. The addition was deleted. en-us Thu, 08 Feb 2024 00:00:00 +0530 Mon, 05 Aug 2024 13:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449431 ITAT Mumbai held that Marketing Contribution, Priority Club receipts, Reservation Contribution and Holidex Fees were not taxable as royalty or fee for included services where they were collected under separate arrangements for common marketing, loyalty programme, reservation support and central reservation system costs, with an obligation to apply the funds for those specified purposes. Prior coordinate bench decisions in the assessee's own case had treated similar receipts as not constituting an unfettered income stream, and the later precedent relied on by the revenue was found inapplicable on these facts. The addition was deleted. Case-Laws Income Tax Thu, 08 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449431