https://www.taxtmi.com/caselaws?id=461650 Income deemed to accrue or arise in India from marketing and reservation contributions was stated by the assessee to be taxable as royalty under the India-US DTAA issue already covered by prior Delhi HC and ITAT rulings in its own case. The assessee also pointed out that the Revenue had accepted the ITAT view for several earlier assessment years and had not filed appeals in those years, while the Assessing Officer had accepted the assessee's position for other years. The Revenue sought time to examine those earlier decisions and file written submissions with supporting authorities. en-us Tue, 26 Nov 2024 00:00:00 +0530 Fri, 18 Apr 2025 19:14:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461650 Income deemed to accrue or arise in India from marketing and reservation contributions was stated by the assessee to be taxable as royalty under the India-US DTAA issue already covered by prior Delhi HC and ITAT rulings in its own case. The assessee also pointed out that the Revenue had accepted the ITAT view for several earlier assessment years and had not filed appeals in those years, while the Assessing Officer had accepted the assessee's position for other years. The Revenue sought time to examine those earlier decisions and file written submissions with supporting authorities. Case-Laws Income Tax Tue, 26 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461650