https://www.taxtmi.com/caselaws?id=755665 Receipts from the loyalty programme, reservation fee and marketing fee were held not to constitute royalty under the Act or Article 12 of the India-Singapore DTAA. The Tribunal followed its co-ordinate Bench's decision in the assessee's own prior year on identical facts and applied the same legal and factual pattern to delete the addition. The related interest issue was left to be recomputed in accordance with law as a consequence of the revised tax position, and the penalty issue was treated as academic after deletion of the addition. 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 Receipts from the loyalty programme, reservation fee and marketing fee were held not to constitute royalty under the Act or Article 12 of the India-Singapore DTAA. The Tribunal followed its co-ordinate Bench's decision in the assessee's own prior year on identical facts and applied the same legal and factual pattern to delete the addition. The related interest issue was left to be recomputed in accordance with law as a consequence of the revised tax position, and the penalty issue was treated as academic after deletion of the addition. Case-Laws Income Tax Tue, 02 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755665