2020 (1) TMI 1484

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....led 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 rendering various services such as sales and marketing,....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ide 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 2013. During the year, the assessee derived income from Indi....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....f 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 the time of hearing the Ld. AR submitted that in the previous years, the Tribunal has decided the cont....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... 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 order is confirmed by the Hon'ble Delhi High Court. 6. The Ld. DR relied upon the order of the Assessi....