https://www.taxtmi.com/caselaws?id=750757 Centralized services fee received for integrated marketing, publicity, sales promotion and reservation-related services was held not to constitute fees for technical services or fees for included services, because the predominant object of the arrangement was commercial support and the ancillary elements did not change its character. The services were rendered outside India, and the treaty conditions for fees for included services were not satisfied, including the requirement that the services be ancillary and subsidiary to a royalty-bearing right. In the absence of a permanent establishment in India, the receipts were taxable only as business income and could not be taxed in India. en-us Tue, 16 Jan 2024 00:00:00 +0530 Mon, 01 Apr 2024 09:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=750757 Centralized services fee received for integrated marketing, publicity, sales promotion and reservation-related services was held not to constitute fees for technical services or fees for included services, because the predominant object of the arrangement was commercial support and the ancillary elements did not change its character. The services were rendered outside India, and the treaty conditions for fees for included services were not satisfied, including the requirement that the services be ancillary and subsidiary to a royalty-bearing right. In the absence of a permanent establishment in India, the receipts were taxable only as business income and could not be taxed in India. Case-Laws Income Tax Tue, 16 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=750757