https://www.taxtmi.com/caselaws?id=461644 Centralized services fees received from Indian hotels were treated as business income rather than fees for technical services or fees for included services, because binding jurisdictional precedents on substantially identical group arrangements held that such receipts do not fall within section 9(1)(vii) or Article 12(4)(a) of the India-US DTAA. In the absence of a permanent establishment in India, the receipts were not taxable under Article 7. The Revenue did not dislodge the applicability of those precedents, so the tax addition on centralized services receipts failed. en-us Tue, 20 Jun 2023 00:00:00 +0530 Fri, 18 Apr 2025 19:14:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461644 Centralized services fees received from Indian hotels were treated as business income rather than fees for technical services or fees for included services, because binding jurisdictional precedents on substantially identical group arrangements held that such receipts do not fall within section 9(1)(vii) or Article 12(4)(a) of the India-US DTAA. In the absence of a permanent establishment in India, the receipts were not taxable under Article 7. The Revenue did not dislodge the applicability of those precedents, so the tax addition on centralized services receipts failed. Case-Laws Income Tax Tue, 20 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461644