https://www.taxtmi.com/caselaws?id=769545 Payments for centralized marketing and reservation services were held not to constitute fees for technical services under domestic tax law or fees for included services under the DTAA; the court relied on prior HC precedents applying service characterisation principles to similar centralized hotel management payments and found those decisions controlling. Because earlier HC rulings consistently favored the taxpayer on identical issues and no substantial question of law arose, the appeal was dismissed and the revenue's claim of taxability on these service receipts was rejected. en-us Thu, 17 Apr 2025 00:00:00 +0530 Mon, 09 Feb 2026 14:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769545 Payments for centralized marketing and reservation services were held not to constitute fees for technical services under domestic tax law or fees for included services under the DTAA; the court relied on prior HC precedents applying service characterisation principles to similar centralized hotel management payments and found those decisions controlling. Because earlier HC rulings consistently favored the taxpayer on identical issues and no substantial question of law arose, the appeal was dismissed and the revenue's claim of taxability on these service receipts was rejected. Case-Laws Income Tax Thu, 17 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769545