https://www.taxtmi.com/caselaws?id=313171 Centralized service receipts from sales and marketing, reservation, loyalty programmes and related support were treated as part of an arrangement for advertisement, publicity, marketing and sales promotion, not as fees for technical services or fees for included services. The Tribunal applied its earlier ruling in the assessee's own case, affirmed by the jurisdictional High Court, and held that the services were neither ancillary or subsidiary to any royalty-bearing right nor within the treaty conditions for fees for included services. Accordingly, the receipts fell outside section 9(1)(vii) and Article 12(4) of the India-USA DTAA and, in the absence of a permanent establishment in India, were taxable only as business income. en-us Fri, 22 Sep 2023 00:00:00 +0530 Thu, 28 Mar 2024 17:30:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=313171 Centralized service receipts from sales and marketing, reservation, loyalty programmes and related support were treated as part of an arrangement for advertisement, publicity, marketing and sales promotion, not as fees for technical services or fees for included services. The Tribunal applied its earlier ruling in the assessee's own case, affirmed by the jurisdictional High Court, and held that the services were neither ancillary or subsidiary to any royalty-bearing right nor within the treaty conditions for fees for included services. Accordingly, the receipts fell outside section 9(1)(vii) and Article 12(4) of the India-USA DTAA and, in the absence of a permanent establishment in India, were taxable only as business income. Case-Laws Income Tax Fri, 22 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=313171