https://www.taxtmi.com/caselaws?id=754090 Receipts from system fund support fee and technology services fee were held not to be fees for technical services or fees for included services under section 9(1)(vii) and Article 12 of the India-USA DTAA because the underlying marketing, reservation and distribution support did not involve technical or consultancy services and did not make available technical knowledge, skill, know-how or processes. Travel agent commission recovered from third-party hotels was likewise treated as a cost-to-cost pass-through recovery, not consideration for managerial, technical or consultancy services, and therefore fell outside the same charging provisions. The Tribunal also followed its earlier years' approach on the same commercial model. The related additions were deleted. 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 Receipts from system fund support fee and technology services fee were held not to be fees for technical services or fees for included services under section 9(1)(vii) and Article 12 of the India-USA DTAA because the underlying marketing, reservation and distribution support did not involve technical or consultancy services and did not make available technical knowledge, skill, know-how or processes. Travel agent commission recovered from third-party hotels was likewise treated as a cost-to-cost pass-through recovery, not consideration for managerial, technical or consultancy services, and therefore fell outside the same charging provisions. The Tribunal also followed its earlier years' approach on the same commercial model. The related additions were deleted. Case-Laws Income Tax Thu, 09 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754090