https://www.taxtmi.com/caselaws?id=754090 ITAT Delhi held that marketing and reservation related receipts including System Fund support fee and Technology Services Fees are not taxable as Royalty/FTS under India-USA DTAA, following consistent ITAT Mumbai decisions for earlier assessment years. Regarding Travel Agent Commission (TACP), the tribunal ruled that commission charged by the assessee for booking hotel rooms on behalf of Indian hotels cannot be treated as FTS under section 9(1)(vii) as the assessee merely facilitated bookings without rendering managerial, technical or consultancy services. The tribunal relied on HC precedents establishing that commission charged by agents outside India is not taxable in India. Appeal decided in favor of assessee. en-us Thu, 09 May 2024 00:00:00 +0530 Mon, 17 Jun 2024 17:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754090 ITAT Delhi held that marketing and reservation related receipts including System Fund support fee and Technology Services Fees are not taxable as Royalty/FTS under India-USA DTAA, following consistent ITAT Mumbai decisions for earlier assessment years. Regarding Travel Agent Commission (TACP), the tribunal ruled that commission charged by the assessee for booking hotel rooms on behalf of Indian hotels cannot be treated as FTS under section 9(1)(vii) as the assessee merely facilitated bookings without rendering managerial, technical or consultancy services. The tribunal relied on HC precedents establishing that commission charged by agents outside India is not taxable in India. Appeal decided in favor of assessee. Case-Laws Income Tax Thu, 09 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754090