https://www.taxtmi.com/caselaws?id=461649 Payments for centralized hotel services were held not to be fee for technical services under section 9(1)(vii) or fee for included services under Article 12(4)(a) of the Indo-US DTAA where the dominant character of the arrangement was marketing, publicity and sales promotion, and the remaining services were merely incidental. The analysis followed an earlier binding decision on similar hotel-related services and accepted the factual findings as not shown to be perverse. On that basis, no substantial question of law was found to arise, and the payments retained their non-FTS character. en-us Wed, 10 Apr 2024 00:00:00 +0530 Fri, 18 Apr 2025 19:14:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461649 Payments for centralized hotel services were held not to be fee for technical services under section 9(1)(vii) or fee for included services under Article 12(4)(a) of the Indo-US DTAA where the dominant character of the arrangement was marketing, publicity and sales promotion, and the remaining services were merely incidental. The analysis followed an earlier binding decision on similar hotel-related services and accepted the factual findings as not shown to be perverse. On that basis, no substantial question of law was found to arise, and the payments retained their non-FTS character. Case-Laws Income Tax Wed, 10 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461649