https://www.taxtmi.com/caselaws?id=314552 Payments for centralized services were held not to constitute fee for technical services under section 9(1)(vii) of the Income-tax Act or fee for included services under Article 12(4)(a) of the Indo-US DTAA. The Delhi HC noted that the issue had already been decided in favour of the assessee in Sheraton International Inc., that no distinguishing feature was shown, and that the earlier decision had not been stayed and continued to bind. On that basis, the revenue appeal was governed by the prior judgment and no substantial question of law survived. en-us Wed, 16 Nov 2022 00:00:00 +0530 Wed, 19 Jun 2024 08:34:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=314552 Payments for centralized services were held not to constitute fee for technical services under section 9(1)(vii) of the Income-tax Act or fee for included services under Article 12(4)(a) of the Indo-US DTAA. The Delhi HC noted that the issue had already been decided in favour of the assessee in Sheraton International Inc., that no distinguishing feature was shown, and that the earlier decision had not been stayed and continued to bind. On that basis, the revenue appeal was governed by the prior judgment and no substantial question of law survived. Case-Laws Income Tax Wed, 16 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=314552