Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2020 (1) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2020 (1) TMI 1484 - AT - Income TaxIncome accrued in India - Centralized services fee received by the appellant for rendering various services such as sales and marketing, Loyalty Programs, Reservation Service, Technological Service, Operational Services and Training Program etc. to customers in India - whether taxable as “Fees for Technical Services” (FTS) in terms of Section 9 of the Income Tax Act, 1961 as well as Article 12 of the India US Double Taxation Avoidance Agreement (DTAA) - HELD THAT:- The issue in respect of taxability of marketing fee and amounts received under Frequent Flier and Starwood Preferred Guest (FFP/SPG) programs is already decided in assessee’s favour by the Hon’ble Delhi High Court in its group concerns M/s Sheraton International LLC [2009 (1) TMI 27 - DELHI HIGH COURT] - Therefore, following the decision of the Hon’ble Delhi High Court, despite the fact that the SLP is pending before the Hon’ble Supreme Court, we are dismissing this appeal of Revenue.
|