https://www.taxtmi.com/caselaws?id=314051 Centralized sales, marketing, reservation, loyalty and related hotel support services rendered under an integrated business arrangement were held not to constitute fee for technical services under section 9(1)(vii) or fees for included services under Article 12(4)(a) or 12(4)(b) of the India-US DTAA. The receipts were not consideration for use of any trademark, right, property or information, were not ancillary or subsidiary to any royalty-bearing arrangement, and the make-available condition was not satisfied. Following binding decisions in the assessee's own and connected cases, the receipts were treated as business income; in the absence of a permanent establishment in India, they were not chargeable to tax in India. en-us Fri, 22 Sep 2023 00:00:00 +0530 Tue, 14 May 2024 19:14:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=314051 Centralized sales, marketing, reservation, loyalty and related hotel support services rendered under an integrated business arrangement were held not to constitute fee for technical services under section 9(1)(vii) or fees for included services under Article 12(4)(a) or 12(4)(b) of the India-US DTAA. The receipts were not consideration for use of any trademark, right, property or information, were not ancillary or subsidiary to any royalty-bearing arrangement, and the make-available condition was not satisfied. Following binding decisions in the assessee's own and connected cases, the receipts were treated as business income; in the absence of a permanent establishment in India, they were not chargeable to tax in India. Case-Laws Income Tax Fri, 22 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=314051