https://www.taxtmi.com/caselaws?id=755665 ITAT Delhi held that receipts under Loyalty Programme, Reservation Fee and Marketing Fee by a Singapore incorporated company cannot be classified as royalty under the India-Singapore DTAA. The tribunal followed its earlier decision in assessee's own case for AY 2015-16, directing deletion of additions made by AO and DRP. Additionally, ITAT directed AO to apply correct tax rates as per DTAA provisions instead of domestic rates inclusive of surcharge and education cess in the final assessment order. en-us Tue, 02 Jul 2024 00:00:00 +0530 Tue, 16 Jul 2024 15:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755665 ITAT Delhi held that receipts under Loyalty Programme, Reservation Fee and Marketing Fee by a Singapore incorporated company cannot be classified as royalty under the India-Singapore DTAA. The tribunal followed its earlier decision in assessee's own case for AY 2015-16, directing deletion of additions made by AO and DRP. Additionally, ITAT directed AO to apply correct tax rates as per DTAA provisions instead of domestic rates inclusive of surcharge and education cess in the final assessment order. Case-Laws Income Tax Tue, 02 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755665