2020 (1) TMI 1484

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.... SUCHITRA KAMBLE, J. This appeal is filed by the Revenue against the order of the Commissioner of Income Tax [Appeals]-43, New Delhi dated 26.07.2016 for Assessment Year 2013-14. 2. The Grounds of appeal are as under:- (i) "Whether on the facts and in the circumstances of the case, the CIT (A) has erred in holding that the Centralized services fee received by the appellant for rende....

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....s of the hotels covered by the agreement through its worldwide system of sales, advertising, promotion, public relations and reservations, in the usual course of it business to some hotels owned/managed by the Indian companies. All such services are provided outside India. For the relevant assessment year, the assessee filed its return of income declaring income of Rs. 6,63,45,204/- on 31st July 2....

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....the assessee on account of SPP/SPG programs are also in the nature of FTS taxable in the hands of the assessee. The assessment u/s 143(3) r.w.s. 144C(3) of the Act has been completed at an income of Rs. 35,08,94,464/- after making various additions. 4. Being aggrieved by the assessment order, the assessee filed appeal before the CIT(A). The CIT(A) allowed the appeal of the assessee. 5. At th....

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....ve Petitions in case of Sheraton International Inc. The Assessing Officer further held that in order to keep the issue alive, it is held that revenue received by the assessee for providing centralized services is liable to be tax as FTS/FIS both under the Act and under the Treaty. Thus, the Ld. AR submitted that the issue is decided in favour of the assessee by the Tribunal as well as the said ord....