https://www.taxtmi.com/caselaws?id=449679 Receipts from centralized hotel-related services such as marketing, publicity, reservations, loyalty programmes, operational support, and training were held to be business income rather than fees for technical services or fees for included services under section 9(1)(vii) and Article 12 of the India-USA DTAA. The Tribunal noted that the arrangement was principally for advertisement, marketing, and promotion, and that the treaty requirements for fees for included services, including the make available condition, were not satisfied. In the absence of a permanent establishment in India, the receipts were not taxable in India. en-us Tue, 13 Feb 2024 00:00:00 +0530 Mon, 10 Jun 2024 15:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449679 Receipts from centralized hotel-related services such as marketing, publicity, reservations, loyalty programmes, operational support, and training were held to be business income rather than fees for technical services or fees for included services under section 9(1)(vii) and Article 12 of the India-USA DTAA. The Tribunal noted that the arrangement was principally for advertisement, marketing, and promotion, and that the treaty requirements for fees for included services, including the make available condition, were not satisfied. In the absence of a permanent establishment in India, the receipts were not taxable in India. Case-Laws Income Tax Tue, 13 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449679