https://www.taxtmi.com/caselaws?id=752634 Receipts from centralized hotel-related support services were held to be business income arising from an integrated marketing and sales-promotion arrangement, not fees for technical services, fees for included services, or royalty. The services were provided from outside India and were directed to publicity, reservation, loyalty and related support functions, without any use of trademark, property or technical know-how. The treaty conditions for fees for included services were not met because the services were neither ancillary to a royalty-bearing right nor did they make available technical knowledge. In the absence of a permanent establishment in India, the receipts were not taxable in India. en-us Tue, 16 Jan 2024 00:00:00 +0530 Wed, 15 May 2024 08:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752634 Receipts from centralized hotel-related support services were held to be business income arising from an integrated marketing and sales-promotion arrangement, not fees for technical services, fees for included services, or royalty. The services were provided from outside India and were directed to publicity, reservation, loyalty and related support functions, without any use of trademark, property or technical know-how. The treaty conditions for fees for included services were not met because the services were neither ancillary to a royalty-bearing right nor did they make available technical knowledge. In the absence of a permanent establishment in India, the receipts were not taxable in India. Case-Laws Income Tax Tue, 16 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752634