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2022 (7) TMI 674 - AT - Income TaxIncome accrued in India - Taxability of payment received by the assessee from Indian hotel owners pursuant to the International Marketing Program Participation Agreement (“IMPPA‟) - HELD THAT:- From the perusal of comparative table of agreements involved in Marriott International Inc. and in the case of assessee, which is forming part of the impugned order, it is evident that both the agreements are broadly similar in respect of nature of services and consideration received. Thus, respectfully following the aforesaid decision in MARRIOTT INTERNATIONAL INC C/O. MARRIOTT HOTELS INDIA PRIVATE LIMITED [2022 (5) TMI 730 - ITAT MUMBAI] we deem it appropriate to set aside all the grounds raised in assessee‟s appeal to the file of the assessing officer with similar directions, as passed in the aforesaid decision.
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