https://www.taxtmi.com/caselaws?id=780264 ITAT (Del-AT) held that marketing-related receipts (MRC) are not taxable as royalty or fees for technical services, following coordinate bench and HC precedent, and allowed the appeals on that ground. Receipts characterized as travel agent commission/program charges for booking Indian hotels were held not to constitute FTS under s.9(1)(vii) or the India-US DTAA. The tribunal remanded the short TDS-credit issue to the AO, directing grant of TDS credit or consideration of refund claims in accordance with law. en-us Fri, 24 Oct 2025 00:00:00 +0530 Mon, 27 Oct 2025 09:17:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780264 ITAT (Del-AT) held that marketing-related receipts (MRC) are not taxable as royalty or fees for technical services, following coordinate bench and HC precedent, and allowed the appeals on that ground. Receipts characterized as travel agent commission/program charges for booking Indian hotels were held not to constitute FTS under s.9(1)(vii) or the India-US DTAA. The tribunal remanded the short TDS-credit issue to the AO, directing grant of TDS credit or consideration of refund claims in accordance with law. Case-Laws Income Tax Fri, 24 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780264