https://www.taxtmi.com/caselaws?id=313134 Centralized services fee received under the India-US DTAA was analysed as part of an integrated business arrangement for advertising, publicity, marketing, sales promotion and hotel reservations. The services were held not to qualify as fees for included services because they were neither ancillary nor subsidiary to the licence arrangement under Article 12(4)(a), and the make-available condition for technical services was not satisfied. The fee was therefore treated as business income rather than royalty or technical services income. In the absence of a permanent establishment in India, the amount was not taxable in India. en-us Thu, 15 Sep 2022 00:00:00 +0530 Wed, 27 Mar 2024 18:11:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=313134 Centralized services fee received under the India-US DTAA was analysed as part of an integrated business arrangement for advertising, publicity, marketing, sales promotion and hotel reservations. The services were held not to qualify as fees for included services because they were neither ancillary nor subsidiary to the licence arrangement under Article 12(4)(a), and the make-available condition for technical services was not satisfied. The fee was therefore treated as business income rather than royalty or technical services income. In the absence of a permanent establishment in India, the amount was not taxable in India. Case-Laws Income Tax Thu, 15 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=313134