https://www.taxtmi.com/caselaws?id=769545 Receipts from centralised marketing, reservation contribution and reservation system support services under inter-company hotel arrangements were held to be outside the Revenue's proposed treatment as fees for technical services or fees for included services under the Act and the India-USA DTAA. The Court noted that the issue had already been covered by its prior decisions in earlier assessment years, so the controversy stood concluded against the Revenue. On that basis, no substantial question of law arose in the section 260A appeal, and the Revenue's challenge failed. 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 Receipts from centralised marketing, reservation contribution and reservation system support services under inter-company hotel arrangements were held to be outside the Revenue's proposed treatment as fees for technical services or fees for included services under the Act and the India-USA DTAA. The Court noted that the issue had already been covered by its prior decisions in earlier assessment years, so the controversy stood concluded against the Revenue. On that basis, no substantial question of law arose in the section 260A appeal, and the Revenue's challenge failed. Case-Laws Income Tax Thu, 17 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769545